Privacy Policy

Last Updated:July 1,2026

Welcome to Hitop!

Hitop is an interactive entertainment application designed to enable seamless communication through voice and text.

To help you foster genuine connections within a safe and inclusive environment, we have established this Privacy Policy (the "Policy"). This Policy outlines how we collect, use, disclose, and safeguard your personal data when you use Hitop or otherwise interact with us. Please read this document carefully. Please note that this Policy applies to every instance of your use of Hitop (which includes the Hitop mobile application, website, and any other related services,hereinafter collectively referred to as "Hitop," the "App," or the "Services").

While we have made every effort to ensure this Policy is clear and transparent, you may still have questions. If you require any clarification regarding this Policy or the handling of your personal data, please contact our privacy compliance team at privacy@imhitop.com.

Please note that we rely on our Terms of Service as a legal basis for processing your personal data under this Section 3. Remember that these terms constitute a contract between you and us.

1. WHO WE ARE

Hitop is published and operated by FUNETICS PTE. LTD., a Singapore company.For the purpose of applicable data protection laws (including the General Data Protection Regulation (GDPR)), the data controller responsible for your personal data is:

2. DATA WE COLLECT

We collect your information in three ways i) information that you provide, ii) automatically collected information, and iii) information from other sources. More detail is provided below.

2.1 Information that You Provide

We collect information you voluntarily share with us when you register an account, set up your profile, use our interactive features, or conduct transactions.

**Phone Sign-up: Phone number, country/area code, and verification codes.

**Email Sign-up: Email address, and email verification codes.

**Basic Profile: Nickname, avatar/profile picture, gender, age, date of birth, country, personal bio, background images, and public or locked photo albums.

**Preferences: Language settings.

**Chat and Instant Messaging (IM): Messages sent via our IM system, including text, custom payloads, and files you choose to share.

**Media and Files: Photos, videos, and image assets uploaded to your profile, albums, posts, or room covers.

**Social Interactions: Text and media content in your dynamic posts, likes, comments, search keywords, and your social graph (including follower lists, and mutual connections).

**Voice Rooms and Audio Features: Room configurations (room ID, name, tags), microphone audio streams during voice sessions or private calls, microphone permission inputs, call configurations, and user roles/permissions within rooms.

If you report a user or content on Hitop, request help, make a claim, participate in a survey, or exercise your privacy rights (as mentioned in Section 8 below), we will process the information contained therein. We will also process information if another user reports you. This kind of information is neither shared nor visible to other users.

2.2 Automatically Collected Data

When you access or use the Services, we automatically collect certain technical, device, and network log data necessary to provide, secure, and optimize Hitop.

**Push Notifications: Push notification tokens (such as FCM tokens), environment parameters, and message data keys required to route notifications to your device.

**Call and Voice Room Logs: Voice call IDs, caller/callee identities, call statuses, connection timeouts, session durations, billing/settlement metrics, reward values, and session termination reasons.

**Local Cache Data: Search history, pending system synchronizations, pending order validations, and localized balance caches stored securely in your device's local storage (e.g., SharedPreferences and local Room databases).

**App Performance: System crash reports, error logs, and environmental diagnostic data collected to maintain app stability.

**Hitop Wallet and Balances: Current balances, currency types, and frozen amounts.

**Transaction Logs: Transaction IDs, amounts, post-transaction balances, business types, associated transaction IDs, creation timestamps, descriptions, and titles.

**Purchase Adjustments: Records related to currency exchanges, top-ups, deductions, frozen funds, area sources, order numbers, and descriptions.

2.3 Information from Other Sources

We may receive information about you from third-party services, partners, or software development kits (SDKs) integrated into our application.

**We receive real-time connection telemetry, audio-room session metadata, and system payload data via communication infrastructure partners to enable high-quality instant messaging, voice rooms, and private voice calls.

**We receive crash reporting parameters and push notification diagnostics from infrastructure services.

3. HOW WE USE YOUR DATA

We strictly adhere to the principles of "legitimacy, necessity, and transparency" when using the information we collect. The collected information is only used for purposes directly related to Hitop Services, and we will never use it for unstated purposes without your explicit consent. Specific uses are categorized below:

3.1 To Provide and Maintain Hitop Services (Core Functional Use)

We use your information first and foremost to let you normally access, use, and experience all core Services—without this, we can’t deliver the basic services you request. Key scenarios:

• Account management: Use your registered mobile number, third-party login ID, or password to verify identity during login, block unauthorized access, and help with password recovery (e.g., sending verification codes to your bound mobile number).

• Service execution: Use your device info (e.g., camera/microphone permissions, network status) to ensure stable use of certain features; use transaction-related info (e.g., payment method, order details) to process in-app purchases (e.g., virtual asset recharges) and send transaction confirmations.

• Technical support: Use your device model, OS version, and crash logs to fix App malfunctions and optimize service compatibility.

3.2 To Optimize User Experience and Personalize Services

We use your information to tailor Hitop Services to your preferences, improve service quality, and make your interaction with the platform more efficient and engaging. This includes:

• Personalized recommendations: Analyzing your content consumption behavior and stated interests (if you provided them in your profile) to recommend relevant features, UGC content, or events.

• Experience optimization: Using aggregated usage data to adjust the App’s interface layout and optimize loading speeds.

• Customized settings: Applying your language preferences and regional settings (derived from your IP address, with your consent) to display in-app text, time zones, and regional content.

3.3 To Ensure Platform Security and Prevent Risks

Protecting your account, personal info, and the Hitop ecosystem is a top priority. We use your information to identify and reduce risks like fraud, harassment, and platform rule violations:

• Anti-fraud & account security: Monitor login behavior (e.g., IP address, device ID) to spot abnormal access (e.g., foreign login if you usually log in locally) and trigger security checks; use your bound mobile number to notify you of account changes (e.g., password edits).

• Violation prevention: Analyzing your provided content (e.g., comments) and interaction logs (e.g., in-app messages) to identify/remove illegal/non-compliant content (e.g., hate speech, porn) and take action against violating accounts (per Hitop’s Terms of Service).

• Legal compliance: Using your information to respond to valid law enforcement requests (e.g., providing account records for fraud probes) or meet data protection law obligations.

3.4 To Communicate with You and Provide Customer Support

We use your contact info and interaction data to update you on services, respond to inquiries, and keep communication smooth:

• Service notifications: Sending important updates (e.g.,Hitop Terms of Service/Policy changes) via in-app messages or SMS—these are necessary for service use and can’t be opted out of (unless you cancel your account).

• Customer support: Using your account ID, issue details, and relevant logs (e.g., transaction records for payment complaints) to handle support requests (e.g., fixing missing virtual assets, aiding account recovery) and follow up on progress.

3.5 To Conduct Internal Analysis and Service Improvement (Anonymized/Aggregated Use)

We may anonymize or aggregate your information (i.e., remove identifiers that can link the data to you personally) for internal research, service optimization, or statistical purposes. This type of use does not involve your personal data and will not pose privacy risks.

3.6 Important Notes on Information Use

• No unauthorized use: We never use your info for non-Hitop Service purposes (e.g., selling to third-party advertisers) or expand use beyond this Policy without your prior written consent.

• Consent withdrawal: For non-essential uses (e.g., personalized ads if applicable), you can withdraw consent anytime (e.g., via App "Privacy Settings")—but this may affect access to some personalized features.

• Data minimization: We only process the minimum data needed to achieve the stated purpose.

4. WHO WE SHARE YOUR DATA WITH

4.1 Data We Share

We do not sell personal data, but we can share personal data as described below:

4.2. Data You Share

When you use Hitop, for example by chatting with another user or showing yourself in a voice room, you share personal data with other users. Any information, text, image, or video you share on Hitop is part of your personal data. You should therefore be very careful about the information and content you wish to share online.

Note: We cannot prevent you from sharing data when using our services, nor can we control what users who receive it may do with it. We may send you a warning before you share some private information so that you understand the consequences of your actions.

5. HOW LONG DO WE KEEP YOUR DATA (DATA RETENTION AND DELETION)

5.1 Account Validity Period & Retention Criteria

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Policy, or as permitted or required by applicable laws.To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve our purposes through other means.

5.2 Specific Data Retention Periods

Different categories of data are subject to specific retention limits to ensure we do not hold data longer than necessary, unless a longer retention period is required or permitted by applicable laws. :

5.3 Legal Obligations and Dispute Resolution

Notwithstanding the standard retention periods above, we will retain certain personal data where necessary to:

Once data is no longer required for these specific purposes, it will be securely deleted or completely anonymized so that it can no longer be linked to you.

6. INTERNATIONAL DATA TRANSFER

FUNETICS PTE. LTD. is a Singapore company with affiliates, contractors, and service providers located in several countries around the world. For that reason, FUNETICS PTE. LTD. needs to transfer (via communication, access, storage…) your personal data in other jurisdictions than the one to which you belong, including in countries with different privacy laws and which may not be recognized as "adequate" by the European Commission, especially the United States of America.

Therefore, we implement appropriate safeguards (such as the European Commission’s Standard Contractual Clauses, where EU data protection laws apply) to ensure that all cross-border transfers comply with applicable rules. To obtain a copy of these Standard Contractual Clauses, you can contact our privacy team at the following address: privacy@imhitop.com.

7. DATA SECURITY

Protecting the confidentiality, integrity, and availability of your personal data is a core responsibility of Hitop. We implement a multi-layered security framework—combining administrative, technical, and physical safeguards—to minimize risks of unauthorized access, disclosure, alteration, or destruction of your data. While no security system is entirely impenetrable, we continuously update our measures to keep pace with global security standards and emerging threats. Though we use comprehensive measures to protect your info, no security is 100% foolproof. Risks may come from factors we can’t control—like unauthorized Hitop account access due to weak passwords, shared credentials, or compromised devices (e.g., lost phone, malware infection).To protect your account, we strongly recommend:• Using a unique, complex Hitop password (mix of letters, numbers, symbols) and not reusing it across multiple devices;• Being cautious of unsolicited messages claiming to be Hitop—we’ll never ask for your password, bank details, or full ID via email/SMS.

8. YOUR PRIVACY RIGHTS

FUNETICS PTE. LTD. is committed to providing you with rights regarding your personal data, in accordance with applicable laws.The conditions for exercising these rights may differ according to the applicable laws and regulations. These rights may be limited as provided by applicable laws and regulations, the rights and freedoms of other people, our confidentiality obligations, trade secrets, and/or the protection of intellectual property rights. Where relevant, you will be informed of the reasons why FUNETICS PTE. LTD. could not fulfill all or part of your request.

Here are your privacy rights:

8.1 Right to Access and Confirm (Right to Know)

You have the right to confirm whether we process your personal data and to request access to or a copy of the personal data Hitop holds about you.

8.2 Right to Rectification (Correction and Supplement)

If you find that the personal data Hitop holds about you is inaccurate, outdated, or incomplete (e.g., your bound mobile number or email address has changed), you have the right to request corrections, updates, or supplements to ensure your data remains accurate.

8.3 Right to Erasure (Right to Be Forgotten / Deletion)

You have the right to request that Hitop delete your personal data. This right typically applies if:

The processing of your information violates applicable laws or regulations.

Important Exceptions: We may decline or delay your deletion request if we are legally obligated to retain the data (e.g., anti-money laundering, tax compliance, or mandatory data retention laws), or if the data is required for the establishment, exercise, or defense of legal claims and ongoing fraud investigations. In such cases, we will securely isolate/restrict the data and inform you of the legal basis.

8.4 Right to Restrict or Object to Processing

You have the right to object to or request the restriction of Hitop’s processing of your personal data under certain scenarios:

8.5 Right to Opt-Out of Data Sale, Sharing, or Targeted Advertising

If you reside in jurisdictions like the United States, you have the right to opt-out of the "sale" or "sharing" of your personal data, as well as its use for targeted advertising or cross-context behavioral advertising. Hitop does not "sell" your data for monetary value, but if any third-party analytics/ad tools constitute "sharing" under local laws, you can exercise your opt-out right via our Cookie Settings or account preferences.

8.6 Right to De-linked Automated Decision-Making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you (e.g., under GDPR, Korea PIPA, and US state laws). You can request human intervention, express your point of view, or contest the decision.

8.7 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (e.g., JSON or CSV file) and have the right to transmit that data to another controller or service provider without hindrance, where technically feasible.

8.8 Right to Withdraw Consent

For any data processing activity that relies on your explicit consent (e.g., marketing communications), you have the right to withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of any processing conducted based on consent before its withdrawal.

8.9 Right to Lodge a Complaint with a Supervisory Authority

If you believe Hitop’s processing of your personal data infringes applicable data protection laws, you have the right to lodge a complaint with a competent regulatory authority, such as:

8.10 Global Framework for Exercising Your Rights

To exercise any of your rights listed above, please contact our Data Protection Officer (DPO) or privacy team at privacy@imhitop.com.

To protect your privacy and security, we must verify your identity (or your authorized agent's identity) before processing your request. We may ask you to provide proof of identity or log into your verified account.

We aim to respond to all legitimate requests promptly and within the legal timeframes mandated by your jurisdiction:

Most requests (e.g., one access request per year) are free. However, if your requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable administrative fee or refuse to act on the request.

Please note that we may refuse a request if it violates legal obligations (e.g., retaining tax-related data), harms public interests (e.g., data for public safety probes), or risks others’ privacy (e.g., deleting chat history with another user’s info). We’ll explain the refusal in detail.

9. CHILDREN PRIVACY

Hitop is committed to protecting the privacy and safety of children. In compliance with global data protection and child safety laws,including but not limited to the EU/UK GDPR, the U.S. Children’s Online Privacy Protection Act (COPPA), and other applicable regulations.We do not knowingly target, design our services for, or collect personal data from individuals under the age of 18 (or the legal age of majority in your jurisdiction, whichever is higher).

If we discover that a minor has bypassed our age-verification restrictions and created an account, we will take immediate action in accordance with global legal requirements:

If you are a parent or guardian and believe your child has provided us with personal data, please contact our Privacy Team immediately at: privacy@imhitop.com.

10. COOKIES AND SIMILAR TECHNOLOGIES

10.1 What are Cookies and Similar Technologies?

Cookies are small text files placed on your computer, mobile device, or other hardware by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide reporting information and collect internet log and visitor behavior information. In addition to cookies, Hitop may utilize other similar technologies, such as web beacons, and software development kits (SDKs) (collectively, "Technologies"), to automatically collect certain data when you interact with or use Hitop Services.

10.2 How and Why Hitop Uses Technologies

Hitop uses Technologies for purposes that are strictly necessary for service delivery, as well as for performance, functionality, and marketing/advertising purposes, specifically including:

10.3 Third-Party Cookies and SDKs

Some Tracking Technologies on Hitop Services are operated by third-party service partners, analytics providers (e.g., Google Analytics), and advertising networks. These third parties may collect information about your online activities over time and across different websites or mobile applications. We do not control these third-party technologies, and their use is governed by the respective third parties' privacy policies.

10.4 Managing Your Preferences and Opting Out

Depending on your country, state, or region of residence, you have specific legal rights to control, restrict, or object to the use of non-essential Technologies.

**iOS: Navigate to Settings > Privacy & Security > Tracking, and toggle off permissions for the Hitop application, or turn off "Allow Apps to Request to Track".

**Android: Navigate to Settings > Privacy > Ads, and select "Reset advertising ID" or "Delete advertising ID".

10.5 Scope and Consequences of Disabling Cookies

Please be aware that your opt-out preferences and cookie configurations are strictly browser, device, and application-specific. You will need to adjust these settings separately on every browser and device you use to access Hitop. If you clear your browser cache, delete cookies, or update your browser, your preference settings may be reset. Disabling functional or advertising cookies will not completely remove advertisements from your feed, but it may significantly affect the normal functionality of certain Hitop features, render parts of our services unavailable, or result in a less personalized experience.

11. CONTACT

Should you have any questions concerning the application, interpretation, or enforcement of this Privacy Policy or requests concerning your personal data, you can contact us:

12. UPDATES TO THIS POLICY

We will update this Policy from time to time to take into account any technical, economic, regulatory, or legal evolution, or if we change our practices regarding the processing of personal data.

We will notify you in advance, by any appropriate means, of significant changes to this Policy. Usually, this will be done through an in-app notification. Following advanced notification, your continued use Hitop, means you accept these changes.