PRIVACY POLICY

The following privacy policy (“Privacy Policy”) sets forth fluentinsaying.com policy with respect to information, including personally identifiable data (“Personal Data”) and other information, Company collects from visitors to the Company website located at http://h5.buzz-way.com/ & http://fluentinsaying.com/ (“Website”).  Company, owner and operator of the Website, is a corporation formed under the laws of Hong Kong SAR.

We respect your privacy and are committed to protecting it. The purpose of this Privacy Policy is to inform you what Personal Data we may collect and how it may be used. This statement only applies to this Website.  This Privacy Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein. If you choose to use the Website, your use is hereby deemed acceptance of Company’s practices described in this Privacy Policy.

WHAT INFORMATION DO WE COLLECT AND HOW IS IT USED?

HOW YOUR INFORMATION MAY BE USED

We may use the information collected in the following ways:

LEGAL BASES FOR PROCESSING DATA UNDER THE GENERAL DATA PROTECTION REGULATION (“GDPR”)

We are responsible as a “controller” of your Personal Data under the GDPR and below are the types of lawful basis that we will rely on to collect and process your Personal Data:

WHERE YOUR PERSONAL DATA IS HELD

Personal Data may be held at our offices and those of our affiliates, parent or related companies, third party Personal Data may be held at our offices and those of our affiliates, parent, or related companies, third party agencies, service providers, representatives and agents as described below (see below: “Third Party Use of Personal Information”).

THIRD-PARTY USE OF PERSONAL INFORMATION

Company may share your Personal Data with certain third parties as set forth below:

Legal Requirements: Company may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity or in connection with our own investigation of suspected or actual illegal activity, in which case we may (and you hereby authorize us to) disclose information without subpoenas or warrants served on us, (ii) protect and defend the rights or property of Company, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, (iv) protect against legal liability including to resolve disputes, investigate problems, or enforce our customer contracts.

The Website may share your information with third parties when you explicitly authorize us to share your information. Additionally, the Website may use third-party service providers to service various aspects of the Website. Each third-party service provider’s use of your personal information is dictated by their respective privacy policies. The Website currently uses the following third-party service providers: 

At this time, your personal information is not shared with any other third-party service providers. This list may be amended from time to time in the Website’s sole discretion. 

Except when required by law, Company will not sell, distribute, or reveal your email addresses or other personal information without your consent; however, Company may disclose or transfer personal information collected through the Website to third parties who acquire all or a portion of our business, which may be the result of a merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

ANONYMOUS DATA

From time to time, Company may use anonymous data, which does not identify you alone, or when combined with data from other parties. This type of anonymous data may be provided to other parties for advertising. Examples of this anonymous data may include analytics or information collected from cookies. 

COOKIES

The Website uses cookies to store visitors’ preferences, record user-specific information on what pages users access or visit, ensure that visitors are not repeatedly sent the same banner ads, customize content based on visitors’ browser type or other information that the visitor sends. Cookies may also be used by third-party services, such as Google Analytics, as described herein. 

What are cookies?

A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.  The cookie will collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from third party site, the URL of the linking page.

In addition to cookies, the Website may use web beacons.  Web beacons allow us to count the number of users who have visited or accessed the Website and to recognize users by accessing our cookies. We may employ web beacons to facilitate Website administration and navigation, to track the actions of users of the Website, to compile aggregate statistics about Website usage and response rates, and to provide an enhanced online experience for visitors to the Website. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. A web beacon is often invisible because it is only 1 x 1 pixel in size with no color.  A web beacon can also be known as a web bug, 1 by 1 GIF, invisible GIF, and tracker GIF. 

What are the different types of cookies and how do we use them?

Users may, at any time, prevent the setting of cookies, by the Website, by using a corresponding setting of your internet browser and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. However, if you deactivate the setting of cookies in your Internet browser, not all functions of our Website may be entirely usable.

How can you manage or opt-out of cookies?

Cookies, including those which have already been set, can be deleted from your hard drive. You can also change the preferences/settings in your web browser to control cookies. In some cases, you can choose to accept cookies from the primary site, but block them from third parties. In others, you can block cookies from specific advertisers, or clear out all cookies. Deleting or blocking cookies may reduce functionality of the Website. To learn more about how to reject cookies, visit   www.allaboutcookies.org   or go to the help menu within your internet browser. If you experience any problems having deleted cookies, you should contact the supplier of your web browser.

Opting out of Analytical Performance Cookies

If you would like to opt out of Analytics cookies, please do so by clicking on the links below:

Opting out of Behavioral Advertising Cookies

ADVERTISING

Display Ads

The Website uses Google AdSense to manage all third-party advertising on the Website. Google AdSense serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website. The cookie may collect information relating to your use of the Website, information about your device such as the device’s IP address and browser type, demographic data and, if you arrived at the Website via a link from a third-party site, the URL of the linking page.   

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting.  Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache.

Without cookies you may not be able to take full advantage of the Website content and features.  Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site.

The Website may collect IP addresses and location information to serve personalized ads and pass it to Google AdSense.

Retargeting Ads

From time to time, the Website may engage in remarketing efforts with third-party companies, such as Google, Facebook, or Instagram, in order to market the Website. These companies use cookies to serve ads based on someone’s past visits to the Website. This means, after visiting the Website, you may see an ad for our services. However, your personally identifiable information is not used by any remarketing service other than to present you offers from Company. We use the following third-party service providers for remarketing:

Sponsored Content Tracking Pixels

This Website may engage in sponsored campaigns with various influencer networks, brands, and agencies. All sponsored content is duly disclosed in accordance with the FTC’s requirements. From time to time, these sponsored campaigns utilize tracking pixels (aka web beacons), which may contain cookies to collect data regarding usage and audience. This information is collected by the sponsoring company to track the results of the campaign. As stated above, these pixels may capture your IP address on behalf of the content sponsor. No personally identifiable information collected by the Website is used in conjunction with these tracking pixels.

HOW LONG WILL YOUR PERSONAL INFORMATION BE KEPT

We will keep your personal information while you are visiting the website, or we are providing products or services to you.

We will not retain your personal information for longer than necessary for the purposes set out in this Privacy Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

RIGHTS RELATED TO YOUR PERSONAL INFORMATION

Under laws in certain countries in which we operate, customers and other visitors to our Website from those countries have a right to delete Personal Data about themselves.  We will, upon your request, take reasonable steps to delete your Personal Data.

Please note that while any deletions will be reflected in active user databases (as updated within a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.

Forget – In certain situations, you may request that we erase or forget your Personal Data. To do so, please submit a request to [email protected].

Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions, or when required by law.

CALIFORNIA RESIDENTS

California Residents:  Pursuant to the California Consumer Privacy Act of 2019 (“CCPA”), you have certain rights with respect to your personal information.  For the purposes of this section, personal information is used as defined in the CCPA.  Company reserves the right to verify all requests made pursuant to the CCPA.

Access and Disclosure

You may make a verifiable request that we disclose the categories of personal information we have collected about you, the categories of sources of the personal information we collected about you, the business or commercial purpose for collecting or selling the personal information, the categories of third parties with whom we share your personal information, our use of the personal information and if the personal information was disclosed or sold to third parties, including the categories of personal information sold or disclosed.  You also have the right to make a verifiable request for a copy of the personal information collected about you for the twelve (12) months prior to the date of your request.   To see any categories of personal information we have sold in the last twelve (12) months or opt out of the sale or disclosure of personal information, please refer to the Do Not Sell My Personal Information link on each page of this Website.  Please note that we are not required to:

Deletion Request Rights

You have the right to request that Company delete any of your personal information that we collected from you and retained, subject to certain exceptions.  We may deny your deletion request if retaining the personal information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Children Under 16

We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age.  

No Discrimination

We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

Exercising Your Rights

To exercise the access, disclosure and deletion rights described above, please submit a verifiable request to us by emailing [email protected], Attn: CCPA.

You may only make a verifiable request for access or disclosure twice within a twelve (12) month period.  You may also make a verifiable consumer request on behalf of your minor child. The verifiable consumer request must:

To respond to your request or provide you with personal information, Company must verify your identity or your authority to make the request. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request. For instructions on exercising sale opt-out rights, please refer to the Do Not Sell My Personal Information link on each page of this Website. 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by e-mailing us at [email protected]. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

Timing

We will respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding the verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

SENSITIVE PERSONAL INFORMATION

At no time should you submit sensitive personal information to the Website. This includes your social security number, information regarding race or ethnic origin, political opinions, religious beliefs, health information, criminal background, or trade union memberships. If you elect to submit such information to us, it will be subject to this Privacy Policy. 

CHILDREN’S INFORMATION

The Website does not knowingly collect any personally identifiable information from children under the age of 16. If a parent or guardian believes that the Website has personally identifiable information of a child under the age of 16 in its database, please contact us immediately at [email protected] and we will use our best efforts to promptly remove such information from our records.

LINKS TO OTHER WEBSITES

This Privacy Policy applies only to the Website. The Website may contain links to other websites not operated or controlled by Company (the “Third-Party Sites”). The policies and procedures described here do not apply to the Third-Party Sites. The links from the Website do not imply that Company endorses or has reviewed the Third-Party Sites. We suggest contacting those sites directly for information on their privacy policies.

OTHER TERMS AND CONDITIONS

Your access to and use of the Website may also be subject to any separate agreements or terms and conditions you have signed or agreed to with Company. Please refer to those agreements as needed.

Regardless of any other provision in this Privacy Policy, we reserve the right to disclose any personally identifiable or non-personally identifiable information about you to: (a) fulfill a government request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Website, or other users; or (d) protect, in an emergency, the health and safety of our customers or the general public. This includes exchanging information with third parties and organizations in connection with credit risk reduction and fraud protection.

Changes to Google AdSense Privacy Policy

The Website may change from time to time. As a result, at times it may be necessary for Company to make changes to this Privacy Policy. Company reserves the right to update or modify this Privacy Policy at any time. Please review this policy periodically, and especially before you provide any Personal Data. Your continued use of the Website after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

Google AdSense Programmatic Advertising (Ver 1.1)

The Website works with Google AdSense to manage third-party interest-based advertising appearing on the Website. Google AdSense serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

Google AdSense Partners (companies listed below with whom Google AdSense shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Google AdSense Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Google AdSense publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Google AdSense Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

Last updated: February 24, 2024.