Data Processing And Security Agreement

1. BACKGROUND
This Module applies if you use the Captcha feature (“Feature”). This Module is incorporated into the Data Processing and Security Agreement located at  (“DPSA”). Terms used but not defined in this Module shall have the meaning given to them in the DPSA. In the event of any conflict between the DPSA and this Module, this Module shall apply to the extent of the inconsistency.
2. PROCESSING
We will process the following data in connection with the Feature:
Personal Information
Use
Verification Data (of end user) – Web version: browser language, page URL, status of web worker (if any), verification attempts, browser features, user-agent, screen resolution, page and screen dimensions, page referrer, OS, CPU, canvas value, property hash, browser resize, WebGL information, GPU, time zone, plugins, color depth, web driver, character set, device and cursor position, load time, time stamp, javascript settings, mouse movement, device orientation
We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. We may also anonymise and aggregate this information for purposes of product/service development and improvement. 
Device Data (of end user) – Web version: IP address
We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. 
Device Data and Verification Data (of end user) – App (SDK) version: 
1. Device data:
For iOS: model, carrier information, network condition, public system, settings and properties, system version
For Android: network condition, public system settings and properties, model, system version
2. Information about end user’s activities on your website or app (such as access time and frequency, pages viewed, click behavior, distribution of swipes on screens and stay time)
We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. We may also anonymise and aggregate this information for purposes of product/service development and improvement. 
Device Identifiers (of end user) – App (SDK) version:
For iOS: Identifier for Vendors (IDFV), IP address
For Android: OAID, AAID, SSAID, Widevine ID, IP address
We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. 
Cookie Data (of end user): TDC_itoken 
We use this cookie for the purposes of providing the Feature to you (to identify whether the end user's request originates from the same device).
3. SERVICE REGION
As specified in the DPSA. The main servers for this Feature are in Singapore, the United States and Germany.
4. SUB-PROCESSORS
As specified in the DPSA, including Aceville Pte Ltd..
5. DATA RETENTION
We will store personal data processed in connection with the Feature as follows (unless otherwise required by applicable Data Protection Laws):
Personal Information
Retention Policy
Verification Data (of end user) – Web Version
Stored for 1 year, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Data (of end user) – Web version
Stored for 30 days, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Data and Verification Data (of end user)  – App (SDK) Version 
Stored for 1 year, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Identifiers (of end user) – App (SDK) version
Stored for 30 days, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Cookie Data
This cookie expires when the end user clears their browsing history.
You can request deletion of such personal data in accordance with the DPSA.
6. SPECIAL CONDITIONS
You must ensure that this Feature is only used by end users who are of at least the minimum age at which an individual can consent to the processing of their personal data or that parental consent is obtained for individuals under the minimum age. This may be different depending on the jurisdiction in which an end user is located.
You represent, warrant and undertake that you are solely responsible for your use of the Feature and its respective functions, and you have and will only use the Feature and/or integrate the Feature in your product, service or platform (as applicable) in compliance with (i) applicable laws and (ii) app store rules, agreements, terms or guidelines applicable in respect of the collection, storage, processing, transfer, disclosure, and use of any end user data in connection with your product, service or platform that uses and/or integrates the Feature, including (without limitation) the Apple Developer Agreement, Apple Developer Program License Agreement, App Store Review Guidelines, Google Play Developer Distribution Agreement, Developer Program Policy, Developer API Terms of Service, Google Play Best Practices, and Google Play Developer Resources, in each case as amended or replaced from time to time (“App Store Rules”).
You represent, warrant and undertake that you shall provide all necessary notices, and obtain and maintain all necessary consents from end users, in respect of the processing of their personal data (including their device identifiers) and use of cookies in respect of the Feature, in accordance with applicable laws and App Store Rules, and so as to enable us to comply with the same. You agree you will indemnify and hold Tencent harmless from and against all claims, liabilities, costs, expenses, loss or damage (including consequential losses, loss of profit and loss of reputation and all interest, penalties and legal and other professional costs and expenses) incurred by Tencent arising directly or indirectly from a breach of this requirement.   
You acknowledge, understand and agree that (i) we do not make any representation or warranty or give any undertaking that this Feature will be in compliance with any applicable laws or regulations, and (ii) any reliance on or use of this Feature is at your sole risk.

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Personal Information	Use
Verification Data (of end user) – Web version: browser language, page URL, status of web worker (if any), verification attempts, browser features, user-agent, screen resolution, page and screen dimensions, page referrer, OS, CPU, canvas value, property hash, browser resize, WebGL information, GPU, time zone, plugins, color depth, web driver, character set, device and cursor position, load time, time stamp, javascript settings, mouse movement, device orientation	We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. We may also anonymise and aggregate this information for purposes of product/service development and improvement.
Device Data (of end user) – Web version: IP address	We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required.
Device Data and Verification Data (of end user) – App (SDK) version: 1. Device data: For iOS: model, carrier information, network condition, public system, settings and properties, system version For Android: network condition, public system settings and properties, model, system version 2. Information about end user’s activities on your website or app (such as access time and frequency, pages viewed, click behavior, distribution of swipes on screens and stay time)	We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required. We may also anonymise and aggregate this information for purposes of product/service development and improvement.
Device Identifiers (of end user) – App (SDK) version: For iOS: Identifier for Vendors (IDFV), IP address For Android: OAID, AAID, SSAID, Widevine ID, IP address	We process this data for the purposes of providing the Feature to you, including to ensure the Feature functions as required.
Cookie Data (of end user): TDC_itoken	We use this cookie for the purposes of providing the Feature to you (to identify whether the end user's request originates from the same device).

Personal Information	Retention Policy
Verification Data (of end user) – Web Version	Stored for 1 year, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Data (of end user) – Web version	Stored for 30 days, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Data and Verification Data (of end user) – App (SDK) Version	Stored for 1 year, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Device Identifiers (of end user) – App (SDK) version	Stored for 30 days, unless you request for deletion of such data (in which case such data will be deleted within 7 days).
Cookie Data	This cookie expires when the end user clears their browsing history.

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1. BACKGROUND

2. PROCESSING

3. SERVICE REGION

4. SUB-PROCESSORS

5. DATA RETENTION

6. SPECIAL CONDITIONS