Xena's Privacy Policy

Welcome to Xena. This Privacy Policy ("Policy") applies to the Xena services, including the Xena applications, websites, and related services (collectively referred to as "Services"), provided and controlled by MICO WORLD LIMITED (collectively referred to as "Xena", "we" or "us"), which link to this Privacy Policy.

We are deeply committed to protecting your privacy. This Policy explains how we collect, use, share, and otherwise process your personal information. We suggest you read it in conjunction with our Terms of Service (the "Terms"). If you do not agree with this Policy, please do not use our Services. When you access or use Xena, you agree to our Policy and you consent to our collection, storage, use and disclosure of your personal information as we've set out in this Policy.

This Policy covers the experience we provide for users aged 18 (or the age of majority under your local law) and older on our Platform. If you are under the age of 18 or the age of majority as determined by the laws of your country, please do not use our Services.

We reserve the right to update this Policy from time to time. When we update our Policy, we will notify you by updating the 'Last Updated' date at the top of this Policy or by providing any other notification as required by applicable law. Your continued access to or use of our Services after the Policy has been updated indicates your acceptance of the updated policy. If you do not agree with the updated Policy, please do not use our Services.

This Policy may be translated into other languages for your convenience, any translated version of this Policy conflicts against the English version, this English version prevails.

Summary

This Policy will tell you exactly how your personal data is being protected by us and it is very important for you to know. Here are the topics that we cover:

1. What information we collect
2. How we use the information
3. How do we share your information
4. Data transfer
5. Security
6. Your rights
7. Cookies and other technologies
8. Children and Children Protection
9. Change and revisions to this Policy
10. Contact

1. What information we collect

This section will introduce what and how personal information we collect from you. We may collect the following information from you:

a. Information you provide to us (either directly or through third parties)

• When you register account, you may need to provide your nickname, gender (to protect social authenticity, once confirm, it cannot be changed), date of birth, phone number (if applicable), SMS verification code (if applicable) and avatar. We use this information to create your Xena account for providing the Services in accordance with your request.
• User-generated contents ("UGC"), such as messages, pictures, images, videos, sounds, or other that you upload through our Services;
• Transaction information, such as recharge records, transaction records and history, date, items, amounts. We will not retain and collect your credit card name, number or security number, these payment information will collect by the third-party payment channel (such as Google and Apple).
• User service information. Any information that you provide in communication with us, when you seek our technical or user services support, exercise your right as the information subject. You also consent that we are allowed to keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you).

b. Information we collect when you use our Services

We may collect certain information when you are using our Services. The type of information that we collect may vary, but generally include:

• Device and network information. We collect information from and about the devices you use. For example, we collect information about your hardware and software, such as the application version, screen resolution, network type, devices memory, device ID, GAID, IDFA, IMEI, IMSI, SSID, device model, etc.
• Usage information. We collect information about your activity through our Services. For example, we may collect information about how you interact with Xena, how you communicate with other Xena's users, the time/frequency/duration of your activities, and your use records and actions.
• Location Information. We may collect general geolocation data, such as information derived from your IP address, Wi-Fi network identifiers, or similar sources. Collection of precise GPS data will only occur with your explicit permission, which you can revoke at any time by disabling location access in your device settings. Please note that GPS data is considered sensitive information. If you choose not to provide it, location-based services will be unavailable to you. However, this will not impact your access to other features or services.
• We will infer your approximate country or region based on your SIM card or IP address. This is not precise positioning information, nor is it sensitive personal information. We will not collect your precise location information.
• Chat information and message board information. In order to ensure a harmonious and healthy community environment, we collect the above information to avoid some words that may offend or distress others via your chat information within Xena.
• Login Recovery via Google Play Block Store. To provide a smoother login experience across devices, we may store an encrypted authentication token using Google Play's Block Store. This allows your account to be automatically restored if you reinstall the app or switch to a new device using the same Google account. The token may be backed up to Google Play services and is encrypted to protect your security. This feature is designed to improve your convenience while keeping your account secure. Please note that Google Play's Block Store is provided by Google. We use this service to help improve your login experience, but the management of the token on Google's side is handled by Google.

When accessing our Services, permissions for your location, microphone, and phone camera will only be utilized after you explicitly grant authorization. We will request your consent through in-app notifications or pop-ups when you attempt to use these specific features.

c. Information we collect from third parties

• Third-party social media. If you register through your connected third-party social media account (Apple ID, Google, Facebook), we may collect the nickname, avatar and other information of your third-party media account, depending on your settings in the corresponding third-party social platform.
• Third-Party Services. We may collect information about you from third-party services, such as advertising partners, payment partners and analytics providers. However, please note that this Policy does not and will not extend, which shall be subject to the respective third-party's privacy policies.
• Advertising and attribution partners. To measure the effectiveness of our advertising campaigns and to improve optimization, we may share limited user information with third-party partners such as Google Ads, Google Analytics, Firebase Authentication. This may include device identifiers, in-app events, and — where applicable — your email address or phone number in encrypted form. These identifiers are used solely for ad measurement, attribution, and audience matching. Such processing may occur on your device or through secure transmission channels, and is performed in accordance with our partners' privacy policies. We do not share your contact information in plain text.

2. How we use your information

We may use your information to support your using, improve and manage our Services, and to fulfill our service terms with you. We typically use the information we collect in the following ways:

• help you efficiently access your information after you log in;
• support your using of our Services, including all features provided by our Services, such as chat with others via voice or message, discovering friends, recharge and payment on our Services;
• remember information so you will not have to re-enter it during you visit or the next time you visit Xena;
• provided personalized content and information to you and others;
• provide, improve, test, and monitor the effectiveness of our Services and other necessary operational analysis matters;
• improve and develop our Services and conduct product development to improve your experience;
• use encrypted contact information (such as email address or phone number) locally on your device to help our advertising partners, including Google Ads, Google Analytics, Firebase Authentication, measure advertising effectiveness and deliver relevant advertisements in a privacy-preserving manner. This process does not involve sharing any plain text identifiers with Google or other third parties. We do not use such data for any purpose other than advertising performance analysis and optimization.
• keep security, diagnose or fix technology problems, and to detect, prevent, and respond to actual or potential fraud and illegal activities;
• identify and act upon any violations of our Terms and Policy, any illegal act, unauthorized access or any other unauthorized use;
• manage queries and request from you (such as delete your personal information and your account);
• comply with and enforce legal requirements, agreements, policies and public benefits; and/or
• process is necessary in order to protect vital interests of yours or another users.

Under any where our collection or using of your personal information is based on your consent, you may withdraw such consent at any time with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.

3. How do we share your information

We take appropriate measures to safeguard your rights in accordance with this Policy, only where necessary will we share your personal information with third parties, as followings:

• third party providers such as Apple, Facebook or Google that provide services in support of Xena for the purpose of registering, advertising, analysing, payment processing services, keep security, fraud detection and other reasonable purposes. All third party providing services for us are prohibited from retaining, using, or disclosing your information for any purpose other than providing us with their services in support of the Services.
• TikTok for Business SDK. We integrate the TikTok for Business SDK to help us measure the effectiveness of our advertising campaigns, attribute installs and in-app events, optimize ad performance, and deliver relevant advertisements. This SDK may automatically collect certain information from your device, including device identifiers (such as Google Advertising ID (GAID) and Apple Identifier for Advertisers (IDFA)), IP address, network type, operating system version, and in-app event data. Where applicable, the SDK may also receive encrypted contact information for audience matching and advertising attribution, but only in a non‑plain‑text form. All data collected by the TikTok SDK is processed in accordance with TikTok's own privacy and security policies. You can opt out of interest‑based advertising from TikTok by adjusting your device settings or through TikTok's ad settings where available.
• In certain cases, we may share limited and encrypted user information (such as email addresses or phone numbers) with trusted third-party partners (such as Google Ads, Google Analytics, or Firebase Authentication) for purposes including advertising attribution, campaign performance measurement, user authentication, and audience matching. These partners act as independent data controllers or processors (as applicable) and process such information in accordance with their own privacy and security policies. We only share this data in hashed or pseudonymized form where possible, and solely for the purposes described above.
• if required by law, or if such use is reasonably necessary for the following purposes, we will share your information with law enforcement agencies, public authorities, or other organizations: 1) comply with legal obligations, procedures, or requirements; 2) enforce our terms of service and other agreements and standards, including investigating any potential violations; 3) detect, prevent, or otherwise address security, fraud, or technical issues; or 4) protect the rights, property, or safety of us, our users, third parties, or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud prevention and credit risk reduction).
• our corporate group, we may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide our Services, to improve and optimize our Services, to prevent illegal use and to support users.
• for operational or other reasons, if we undergo a merger, divestiture, restructuring, dissolution, or otherwise sell or transfer assets, we may disclose or share your personal information with the purchaser or other successor. In bankruptcy liquidations or other legal proceedings, the personal information of our users that we hold will be part of the transferred assets. In the event of such a sale or transfer, we will make reasonable efforts to ensure that the entity which receive your personal information continues to process the information in accordance with this Policy.

4. Data Transfer

You understand and agree that your personal information may be processed by us and our trusted third-party vendors outside of your country, including in countries where data privacy laws or regulations may be equivalent to or offer the same level of protection as those in your country. In accordance with applicable data protection and privacy laws and regulations, we will take appropriate measures to ensure that your personal information continues to receive the same level of security protection when transferred outside your jurisdiction.

You understand and agree that, where permitted by applicable data protection and privacy laws and regulations, we may also transfer your personal information outside your country of residence for purposes such as: fulfilling a contract with you (or to take steps at your request before entering into a contract); fulfilling a contract in your interest; related to legal claims; or other circumstances allowed by law or regulations.

5. Security

Xena has implemented reasonable and appropriate security measures to protect the information under our control (including your personal information), such as encrypting your personal data and using firewalls and other technical safeguards. While we take reasonable precautions against possible security breaches of our Services, no website or Internet transmission is completely secure and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe and to log out of your account after use. We cannot guarantee the security of your personal data while it is being transmitted to us. Any transmission is at your own risk. Once we have received your information we have procedures and security features in place to try to prevent unauthorized access.

We caution you that we cannot guarantee the security of your personal information provided to third parties through our Services. Any resulting information leakage or other consequences will be your responsibility. Please consider carefully before providing your information to others.

6. Your rights

You are entitled to all rights established under applicable law, and we will make every effort to accommodate any reasonable and valid requests you submit. You can exercise your rights directly through specific settings within our Services, or by sending us an email. This includes:

a. access and correction

You have the right to access your personal data at any time. We will endeavor to ensure, by implementing suitable measures, that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data in accordance with Applicable Laws.

b. delete your information

If you find that we collect and use your personal information in violation of laws, administrative regulations or the agreement of both parties, without your consent or other reasons which permitted by laws and regulations, you can ask us to delete it. Moreover, when the personal information that we have collected from you are no longer necessary for the purpose for which they were collected, you can ask us to delete it as well.

You can also delete your account by contact us or through our App settings. Once you successfully delete your account, unless otherwise stipulated by laws and regulations, all information under your account will be permanently deleted, including your virtual items, contact records, posted content, etc., and you will not be able to retrieve them. We recommend that you carefully consider deleting your account.

If your personal information is erased at your request or in accordance with our data retention policy, we only retain such information that is necessary to protect our legitimate interests or to comply with a legal obligation.

You knowledge and agree that when you or we assist you in deleting relevant information, we may not immediately delete the corresponding information for reasons of applicable law and security technology, but we will take reasonable steps to store the relevant information securely until such information can be erased or anonymized.

c. withdraw your consent

Some information is required to use our Services, but the provision of most other information is on your decision. You can change the scope of your authorization to us to continue to collect the information or withdraw your authorization by means of deleting information, turning off device functions and so on.

After you withdraw your authorization, we are unable to continue to provide you with the service corresponding to the withdrawal of the authorization, and will not process your corresponding information. However, your decision to withdraw your authorization will not affect the information processing previously based on your authorization.

If you do not wish your contact information (such as your email address or phone number) to be used for advertising attribution or audience matching purposes, you may contact us at contact@xenalive.me or adjust your preferences via Google's Ad settings.

d. Other rights stipulated by applicable laws and regulations.

Within the scope permitted by applicable laws and regulations, we will respond to your requests promptly after verifying your true identity, and assist you in processing them.

7. Cookies and other technologies

We only use cookies and similar technologies to provide necessary identity verification, data analysis, and to maintain the normal operation of H5 web pages. We do not track any of your activities outside our Services through cookie technology, nor do we use it in advertising scenarios.

8. Children and Children Protection

We only provide our Services to adults. If you have not reached the age of adult as stipulated by local legal jurisdiction, please do not use our Services. We do not knowingly collect, use or share any information about children (age rating depends on the country where you reside) without verifiable parental consent or as permitted by law. If we learn that personal information of individuals under the age of adult as stipulated by your local legal jurisdiction has been collected on or through our Services, we will take appropriate measures to delete such information and delete the corresponding account. If you are a parent or guardian and you believe your child has provided us with information, you can contact us via contact@xenalive.me and request your child's information to be deleted from our system.

Please note that as a parent or legal guardian, it is your responsibility to supervise and manage your child's use of our services. If a minor provides false information and claims to be of legal age, you, as the parent or guardian, will assume full responsibility for any consequences arising from such misrepresentation. We strongly encourage parents and guardians to educate their children about the importance of online safety and to monitor their activities to ensure compliance with our policies and applicable laws.

We are deeply committed to the safety and protection of children. To this end, we comply with all applicable laws and regulations and have implemented the following measures to ensure a safe environment:

a. Prohibited Content and Practices

We strictly prohibit any dating or companionship advertisements that:

• Promote underage dating.
• Feature imagery or text on landing pages that misrepresent the users to whom the service markets itself.
• Promote compensated companionship, dating, or sexual acts.
• Promote exploitative or deceptive dating services.
• Promote mail-order spouses.

b. Restricted Categories

We also restrict advertisements for certain dating and companionship services, including (but not limited to):

• Hook-up, fling, or swinger dating sites.
• Affair dating or infidelity services.
• Sexual fetish dating.
• Livestream or chat apps featuring nudity, partial nudity, or sexually suggestive content.
• Advertisements or landing pages with racy content, such as individuals wearing underwear or lingerie, or depictions of topless or bottomless individuals in private settings.

c. Preventing Harm to Children

We prohibit the use of our platform for any activities that endanger children. This includes, but is not limited to:

• Inappropriate interactions targeted at children (e.g., groping or caressing).
• Child grooming (e.g., befriending a child online to facilitate sexual contact or exchange of sexual imagery).
• Sexualization of minors (e.g., imagery that promotes or encourages the sexual exploitation of children).
• Sextortion (e.g., blackmailing a child using intimate imagery).
• Child trafficking (e.g., advertising or soliciting a child for commercial sexual exploitation).

By implementing these policies, we are dedicated to fostering a safe environment that protects and prioritizes the well-being of children. If you suspect a child is at risk or has been subjected to any of the situations mentioned above, please reach out to us at contact@xenalive.me.

9. Change and revisions to this policy

Without affecting your legal rights, we reserve the right to revise this Policy at any time. Please regularly review this Policy to check for such changes. Your continued access to or use of our Services after the effectiveness of the new Policy signifies your acceptance of the new Policy. If you do not agree with the new Policy, please don't use our Services.

10. Contact

If you have any questions about anything in this Policy, or want to exercise any rights you may have, please contact us: contact@xenalive.me.

Our Address: Flat/Rm A 12/F ZJ 300, 300 Lockhart Road, Wan Chai, Hong Kong