Privacy Policy

1. Introduction

VERMILION SUNRISE LIMITED ("we," "our," or "us") operates the Soba mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. By using Soba, you consent to the data practices described in this policy. If you do not agree, please do not access or use the App.

2. Information We Collect

We adhere to the data minimization principle and only collect information essential to provide and improve the App's core functionality.

Information Category	Specific Data Collected	Primary Purpose of Collection & Use
Account Information	Email address, username, and encrypted password.	To create and manage your account, authenticate you, and secure your profile.
User-Generated Content (UGC)	Posts, comments, images, videos, and associated metadata (e.g., time of posting).	To display content within the App and provide the core social sharing features.
Technical & Usage Information	IP address, device type, operating system version, unique device identifiers (e.g., Android ID), and app crash logs.	To ensure the App's stability, perform troubleshooting, and protect against security threats.
Payment Information	Payments are processed entirely by Apple App Store or Google Play. We do not collect or store any payment card or bank account details.	To facilitate in-app purchases.

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide, maintain, and improve the App's functionality.
• To process transactions and manage your account.
• To moderate UGC and enforce our community guidelines.
• To communicate with you, including sending service-related announcements.
• To ensure the security and integrity of the App and prevent fraud.
• To comply with legal obligations.

4. Legal Bases for Processing (For EEA/UK Users)

If you are in the European Economic Area (EEA) or the UK, we process your personal data on the following legal bases:

• Performance of a Contract: To provide the App's core services to you.
• Legitimate Interests: For operations like security, analytics, and improving our services.
• Consent: For optional data processing, which you can withdraw at any time.

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following limited circumstances:

• Service Providers: With trusted third-party vendors who assist us in operating the App (e.g., cloud hosting providers). These partners are contractually bound to handle your data securely and only per our instructions.
• Legal Requirements: If required to do so by law or in response to valid legal processes.
• Business Transfers: In connection with a merger, sale of company assets, or acquisition.
• Public UGC: Content you post publicly (e.g., on your profile) is visible to other users as per your privacy settings. You are solely responsible for such content.

6. Data Security

We implement appropriate technical and organizational security measures designed to protect your personal data, including encryption in transit. However, no method of transmission over the Internet or electronic storage is 100% secure.

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. When data is no longer needed, it will be securely deleted or anonymized.

8. International Data Transfers

As we are based in Hong Kong, your data may be processed outside your country of residence. We ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy.

9. Your Rights and Choices

Depending on your location, you may have the right to:

• Access, correct, or delete your personal data.
• Restrict or object to the processing of your data.
• Data portability.
• Withdraw consent where processing is based on consent.

To exercise these rights, please contact us at holujohnny011@gmail.com. We will respond to your request within 15 business days.

10. Third-Party Services and Links

The App integrates with and uses services from:

• Apple App Store: https://www.apple.com/legal/privacy/en-ww/
• Google Play: https://www.google.com/policies/privacy/

These platforms have their own privacy policies, and we encourage you to review them.

11. Changes to This Privacy Policy

We may update this policy. The "Last Updated" date at the top will indicate changes. We will notify you of any material changes by posting the new policy in the App. Your continued use after such changes constitutes acceptance.

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