Privacy Policy

This privacy policy is applicable to the Spotito app (hereinafter referred to as "Application") for mobile devices, which was developed by HK XINHUA (hereinafter referred to as "Service Provider") as a a Free service. This service is provided "AS IS".

Data and Content Accuracy

The Application provides sports results and statistical data (hereinafter referred to as "Content") as part of its service. This Content is provided on an "AS IS" and "AS AVAILABLE" basis, and is aggregated from various independent third-party sources.

The Service Provider strives to ensure the Application is beneficial and efficient; however, as we rely on these third-party providers for data, the Service Provider does not warrant and cannot guarantee the absolute accuracy, completeness, timeliness, or reliability of any Content displayed within the Application.

Your reliance on any Content from the Application is entirely at your own discretion and risk. We strongly recommend that you verify any information critical to you (such as match times or results) with official sources. The Service Provider accepts no liability for any loss, direct or indirect, that you experience as a result of relying on the Content or functionality of the Application.

For the avoidance of doubt, all Content presented in this Application is independently sourced and is not affiliated with, endorsed, sponsored, or specifically approved by the platform providers through which this Application is distributed, such as Apple Inc. or Google LLC. These platform providers are not the source of, and are not responsible for, the Content or its accuracy.

What information does the Application obtain and how is it used?

User Provided Information

The Application acquires the information you supply when you download and register the Application. Registration with the Service Provider is not mandatory. However, bear in mind that you might not be able to utilize some of the features offered by the Application (such as the Community features) unless you register with them.

When you use the Community features within the Application, the Service Provider collects the content you create, upload, or receive from others. This includes:

Profile information (such as your username and avatar).

User-Generated Content (UGC), including text posts, comments, images, and videos that you publish in the community.

The Service Provider uses this information to operate, maintain, and provide the features and functionality of the Application, as well as to communicate directly with you, such as to send you email messages and push notifications.

Community Guidelines and Content Moderation

Since the Application includes a user community, strictly enforced policies are in place regarding User-Generated Content (UGC):

Zero Tolerance Policy: We have a zero-tolerance policy for objectionable content and abusive users. This includes, but is not limited to, content that is defamatory, discriminatory, pornographic, violent, or promotes illegal acts.

Reporting and Blocking: The Application provides mechanisms for users to flag or report objectionable content and to block abusive users. These features are accessible directly within the content feed.

Content Review: The Service Provider will review reported content and take action within 24 hours. This may include removing the content and ejecting the user who provided the offending content.

Automated and Manual Filtering: We employ systems to filter out objectionable material from being posted.

Automatically Collected Information

In addition, the Application may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the Application.

Does the Application collect precise real time location information of the device?

This Application does not gather precise information about the location of your mobile device.

Do third parties see and/or have access to information obtained by the Application?

Only aggregated, anonymized data is periodically transmitted to external services to aid the Service Provider in improving the Application and their service. The Service Provider may share your information with third parties in the ways that are described in this privacy statement.

Please note that the Application utilizes third-party technical services that have their own Privacy Policy about handling data. Below are the links to the Privacy Policy of the third-party service providers used by the Application:

Google Play Services

Google Analytics for Firebase

Firebase Crashlytics

The Service Provider may disclose User Provided and Automatically Collected Information:

as required by law, such as to comply with a subpoena, or similar legal process;

when they believe in good faith that disclosure is necessary to protect their rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;

with their trusted services providers who work on their behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules set forth in this privacy statement.

User Rights: Deletion and Management

You have the right to manage your data within the Application:

Account Deletion: You can request the deletion of your account directly within the Application settings. Upon deletion, your personal profile and authentication data will be removed from our servers.

Content Deletion: You have the ability to delete any UGC (posts, comments, images, videos) you have published. Once deleted, this content will be removed from public view immediately.

Opt-out: You can halt all collection of information by the Application easily by uninstalling the Application. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

Data Retention Policy, Managing Your Information

The Service Provider will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. The Service Provider will retain Automatically Collected information for up to 24 months and thereafter may store it in aggregate. If you'd like the Service Provider to delete User Provided Data that you have provided via the Application, please contact them at [email protected] and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.

Children

The Service Provider does not use the Application to knowingly solicit data from or market to children under the age of 13.

The Application does not address anyone under the age of 13. The Service Provider does not knowingly collect personally identifiable information from children under 13 years of age. In the case the Service Provider discover that a child under 13 has provided personal information, the Service Provider will immediately delete this from their servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact the Service Provider ([email protected]) so that they will be able to take the necessary actions.

Security

The Service Provider are concerned about safeguarding the confidentiality of your information. The Service Provider provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve their Application. Please be aware that, although we endeavor provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

Effective Date

This privacy policy is effective as of 2026-01-01.

Your Consent

By using the Application, you are giving your consent to the Service Provider processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information.

Contact us

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at [email protected].

Spotito is an online platform operated by BRG365 Inc., based in Hong Kong.