By using the Services, you are deemed to accept the terms of this Policy, and to expressly acknowledge and, where required, consent to our processing of the information you provide to us for the purposes outlined in, or otherwise in accordance with, this Policy. If you do not agree with the terms of this Policy, we may not be able to provide the Services to you.
1. Data We Collect
2. How We Use Your Data
3. Our Legal Basis for Processing Data
4. Data Storage and Retention
5. Data Security and Protection
6. To Whom We May Disclose or Transfer Your Data
7. International Data Transfer
8. Data Access and Management
10. Changes to the Policy
11. Parental and Guardian Consent
12. Contact Information
13. Country / Region Specific Terms
Summary of this Policy
This Policy is an integral part of and incorporated by this reference into the Terms of Service, and all capitalized terms not defined in this Policy will have the meanings set forth in the Terms of Service.
We collect the data provided to us by Snack Video users, such as account information, content uploaded by users, and user interactions with the community. Where in-app purchase or withdrawal features are available, data to complete transactions and/or payment will be further collected to enable such functions. Snack Video may also collect data as you use our services, such as your activities on the platform, your device, and internet information.
We use the data we collect to deliver and maintain our services. We process your data to help you share moments with the community, your search terms to return the results you are looking for, and your queries to provide customer services. Your data may also be used for troubleshooting, improving our services, or developing new ones.
Snack Video may use the data we collect from you to optimize user experience, including recommending content that may be of interest to you. Where it is necessary, we may also use your data to ensure security of the platform, detect and prevent fraud, or comply with our legal or regulatory obligations.
We store your data in our data center located in Singapore. We use and keep your data to the extent that is necessary to achieve the purposes for which it is collected, including to provide our services to you, to fulfil our legal obligations, or to protect our legitimate interests.
You have certain rights in relation to your data, subject to applicable laws. Once you have completed your account registration and verification, you can review, modify, and delete your data. We may need to retain some of your data, like your initial registration information, for verification and security purposes.
You can also ask us to delete your account. This is an irreversible process as you will not be able to access your account upon deletion, and all data in relation to the account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.
Last updated: October 2021
This Policy is drafted in Indonesian and applies to users who reside in Indonesian-speaking regions where Snack Video operates. However, please note that this Policy does not apply to the Europe Economic Area and the United Kingdom where Snack Video does not operate.
We may also have separate versions of this Policy, including English for users in different jurisdictions. If there is any inconsistency between this Policy and any of the special language versions, special language versions shall prevail for residents in the jurisdictions they cover.
If you reside or use our Services in a country or region specifically mentioned under the Section " Country / Region Specific Terms" below, those terms and conditions under the relevant country/region shall specifically apply to you.
In this Policy, “you” or “your” refers to the authorized user of our Services.
We may collect the following categories of Data from and about you:
(1) Registration and contact information, such as email address or phone number, user name, authorized link for social network account registration, age, and other information you choose to provide when creating a profile or submitting a request, including alias, gender, nationality, country or region code, profile images;
(2) Network and device information, such as user ID, password, token, digital certificate, IP address, device ID or characteristics, cookies, advertising identifiers, WiFi/WLAN Bluetooth, mobile network information, app and file names, phone book and/or contact information (subject to your consent);
(3) Network browsing data, such as choices you make when using or interacting with the Services, our community, and/or advertisements (if available), your account preference settings, follow history, followers, likes or participation records in challenges, surveys, contests or other platform activities provided through our Services, and your account social network contact/friend list (subject to your consent);
(4) Financial information, such as a Virtual Item, voucher code, card and account number, third party payment details, records regarding transactions, transfers, orders, withdrawals, rewards, tipping and/or other ID information necessary to identify users/accounts (subject to your consent);
(5) Location data, such as information you provide to the platform relating to your address or location and geolocation information derived from your device information based on your SIM card, IP address, GPS (subject to your consent) and/or WiFi/WLAN information on an ongoing basis;
(6) User generated content, such as the content you provide to us when using our Services or interacting with the platform community through browsing, watching, creating, composing, forwarding, sending, receiving, searching, applying special effects to, downloading or uploading texts, symbols, images, audios, videos, broadcasts, live streams (where applicable), chats, messages, comments, music, films, as well as all the data you provide to us during your communication with customer services, in respect of a question, comment, inquiry, request, dispute, complaint, verification, which may include all attachments uploaded, descriptions and information necessary to verify user identity on an as-needed basis;
(7) Other data inferred from or associated with any of the above, such as any metadata accompanying user generated content, audio-visual clips segmentation, annotation, frame or text extraction, object and image recognition symbolling, aggregated classification tagging and other non-personally identifying information inferred from data you provide to us or that we collect about you in connection with your use of Services.
Other data inferred from or associated with any of the above, such as any metadata accompanying user generated content, audio-visual clips segmentation, annotation, frame or text extraction, object and image recognition symbolling, aggregate classification tagging and other non-personally identifiable information or personally identifiable information (including biometric identifiers, which is solely for content moderation purposes) derived from the data you provide to us or that we collect about you in connection with your use of Services.
The categories and scope of Data we collect about you may vary from time to time, depending on your choice of and interaction with the Services, as well as the country or region in which you use the Services.
Where app features are available, you may choose to browse certain content in the platform before logging in or registering, in which case we may still collect certain data, such as the content you browse, your interactions with the platform, location information (subject to your consent), and associated device information such as device ID, WiFi information and IP address.
We may collect Data from you and about you from the following sources:
(1) From you: We collect information that you voluntarily submit or provide to us, including (without limitation) when you download our app, create an account, interact with the Services, or otherwise contact us with a question, comment, or request.
(2) From your devices: We and our service providers may automatically collect certain network and device information from your computers or mobile devices once you activate our Services, such as your IP address, your geographic location, battery level, browser type, language and version, operating system, app and file names and types, error and service access logs, clipboard information, model of your device, time zone settings, device ID, network type, advertising identifiers, network operator, Wi-Fi information, and user action logs on the platform.
We may use your Data for a number of purposes associated with operating our business and providing the Services to you, including:
(1) Identification and authentication: We use your Data to verify your identity or eligibility when you access and use our Services, such as receiving rewards or prizes, or otherwise engaging with us, and to protect the security of your Data. In some instances, we use your Data to verify your age in order to provide certain Services to you, such as live streaming (where applicable), or to verify your identity in order to fulfill your request in relation to your Data.
(2) Service provision: We process your Data to provide the Services that you request, to respond to your queries, or to contact you about changes to the Services and the platform. This may also include managing the content ecosystem of the Services, enabling app features or special effects, facilitating third party partnerships or integrations with the Services, monitoring and testing the Services, troubleshooting, or allowing you and other users to connect with each other.
(3) Payment processing: We may use your Data for billing and payment processing purposes or to distribute awards to you. This may also include enabling payment through third-party payment systems.
(4) Optimizing your experience: We may use your Data to improve your experience of the Services, such as by providing interactive or personalized elements on the Services, simplifying the operations process when you launch a certain function, recommending to you accounts that you may be interested in, providing you with content based on your interests, enabling you to find friends and social contacts, or making our Services more personalized subject to your permission to provide you with location-based services. In order to improve the efficiency of uploading audio-visual content generated by users, you may enable the preload feature to pre-upload your videos before publication. We may also use information stored on your clipboard to enable you to share it on the Services or with third parties.
(5) Service and algorithm enhancement, development, and research: We inspect and analyze usage information and statistics to maintain and improve the Services and algorithm. We may also use your Data to support customer services and user feedback, conduct survey or research and develop new products and services.
(6) Communications: Communications may include, for example, providing information about our products and services, changes to the terms of service, updates regarding our services, user information reports on users who are minors, or responses to your questions, comments or requests.
(7) Content moderation: We may process your Data to identify the images and audio in the content you create or upload to the Services to detect improper contents.
(8) Marketing, advertising and sales: We may use your Data to build a profile about you, to analyze and understand your preferences, to help determine which marketing materials would be of interest to you, to display advertising, to send you marketing communications, to conduct award activities, to measure the effectiveness of advertising and promotion, and to facilitate sales, purchases and delivery (where applicable). We may also process your Data in the course of giving awards or conducting sweepstakes, contests or other promotions. We may use your Data for direct marketing purposes upon obtaining appropriate consent under applicable laws.
(9) Exercising our rights: We may use your Data to exercise our rights where it is necessary to do so, for example to detect, prevent, investigate and respond to security incidents or breaches, data scrapping, fraud, abuse, intellectual property infringement claims, financial crimes, other violations of law, or violations of our Terms of Service and Community Guidelines.
(10) Complying with our obligations: We may process your Data to comply with legal or regulatory obligations, including without limitation our legal obligation to prevent users under the Minimum Age from accessing the platform, to respond to lawsuits, damages or investigations, within or outside of your country or region or in any instance of mergers, acquisitions, sales and asset transfers, insolvency proceedings, corporate restructuring, winding up or liquidation. We may also aggregate and/or de-identify your Data and may use such aggregate or deidentified information for any other purposes.
(11) Other: We may also use your Data for other purposes which we otherwise inform to you and obtain your appropriate consent.
3. Our Legal Basis for Processing Data
In order to process your Data, we will rely upon the legal bases afforded by applicable laws and regulations. In addition to your consent, which will always be limited to specific processing activities and include relevant, detailed information required for you to fully understand what you are consenting to, these legal bases may also include our compliance with legal obligations, the performance of an agreement with you, and our legitimate interests.
4. Data Storage and Retention
(1) We store your Data on our servers located in Singapore. We also have support, engineering, content moderation, and other functional teams located around the world to support the Services provided to you. We have rigorous internal control measures in place to strictly limit data access to designated personnel only.
(2) We will retain your Data for as long as necessary: (i) to achieve the purposes as set out in this Policy; (ii) as required by applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations; (iii) for our legitimate and lawful purposes, including for our business, and provision of the Services; and/or (iv) to defend against any actual, threatened or potential claims or disputes.
(3) We will not retain your Data for longer than necessary or beyond the end of the purposes for which you provided your Data to us, unless we are required to do so under applicable laws. In addition, we reserve the right to delete, destroy, or de-identify your Data that is no longer necessary or current for the purposes for which it was obtained, such as Data about user accounts that have been inactive for 6 consecutive months, or where the specific time period required under applicable laws have lapsed.
5. Data Security and Protection
(1) We will take appropriate technical and organizational measures to help protect and secure your Data. We will endeavor to protect your Data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:
(i) using encryption techniques;
(ii) establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your Data, and requiring those who have such access to comply with relevant confidentiality obligations; and
(iii) forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements.
(2) We will endeavor to ensure that, by default, we only collect and process your Data needed to provide the Services. We also apply this principle to our data privacy and protection controls into our processing activities. This means that we will neither publish nor share your Data by default.
(3) While we are committed to protecting your Data, no electronic data transmission or storage of information can be completely secure. Therefore, although we take appropriate technical and organizational measures to secure your Data, we do not guarantee, and you should not expect, that your Data will always remain secure. If you do not agree to these risks and conditions, you must discontinue your use of the Services.
(1) We will not share or transfer any of your Data to any third parties except as explicitly provided in this Policy. We will only share your Data with third parties in the following circumstances:
(i) when approved or authorized by you or subject to the “ Parental and Guardian Consent” section below, your parent or legal guardian;
(ii) as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;
(iii) in any legal proceedings (including arbitrations) against you in which we aim to protect our legal rights;
(iv) where expressly allowed by the Terms of Service;
(v) in order to protect the interests of the Company, you or the public against harm; or
(vi) pursuant to the agreements made by you with any other third parties.
(2) We may share your Data with our corporate affiliates, group members, and the following third parties, who will only use your Data in accordance with this Policy to facilitate the provision of the Services to you or for other purposes as indicated below.
a) Social media platforms: To facilitate the provision of the Services to you, we may share your Data with social media platforms of your choice: If you access the Services through third party social media platforms (such as Facebook, Google, Twitter, Apple), we share certain information about you (such as account ID, access token and referring URL) with your selected platform. If you allow third party social media integrations with the Services or share the content of Services on third party platforms (such as YouTube, Instagram, Facebook, Twitter, WhatsApp), depending on the content you choose to share, we may share certain information about you (such as account ID, user ID, photo ID and share URL) with your selected platform.
b) In the context of a transaction including mergers, acquisitions or asset sales: We may transfer your Data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event. In order to develop our business, we may engage in transaction such as mergers, acquisitions, sales and asset transfers. In these circumstances, we will inform you of the related transactions, and will continue to protect or require the successor to protect your Data in accordance with applicable laws and regulations and this Policy.
c) Third parties in support of the Services: We may engage third parties to perform functions on our behalf or to provide services to us such as professional agencies and individuals, including advisors, auditors, lawyers and accountants. We share your Data with these service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services. We will only share your Data on a need-to-know basis with third parties in order for them to perform corresponding services on our behalf, and we will request such parties to maintain appropriate security measures to protect such Data from unauthorized access or processing.
d) Legal, regulatory or government authorities: We may in limited cases transfer your Data to local (where you reside) or overseas authorities such as legal, regulatory, law enforcement, government and tax authorities, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations.
e) Promotions: If you choose to register for a promotion, such as a competition, sweepstakes, lucky draw, contest, reward program for user or creators, your Data may be disclosed to third parties for the purposes of administering such promotion.
f) Advertisers and measurement service providers: Where advertising services are available to users, we share aggregate information, which no longer contains personal data, with advertisers and third-party measurement service providers to show the amounts and groups of users of our platforms who have viewed or clicked on an advertisement. We share your device ID with technical attribution companies so that we may connect your activities on our platforms with your activities on other apps or websites to recommend advertising content which may be of interest to you.
g) Other third parties: We may share anonymized or de-identified data with other parties not listed above. If we do this, you will not be identifiable from this data.
(3) You may submit certain information through the Services (e.g., upload short videos). Any such information that is meant to be shown to the public on our app will be disclosed publicly. This Policy does not apply to uses of any such information by third parties after it is uploaded and displayed on the Services.
(4) Except as otherwise provided in this Policy, we will not disclose any of the Data collected from your use of the Services to the public. If public disclosure is required by applicable laws and regulations, we will inform you of the purpose of the disclosure and the type of information disclosed.
7. International Data Transfers
We may transfer your Data to other countries or regions solely for the purposes set out in this Policy, in accordance with this Policy and applicable laws and regulations.
Data disclosure as referred to in this Policy may involve a transfer of your Data to countries and regions that provide different levels of data protection. Applicable legal and regulatory requirements are taken into consideration before any cross-border transfer of your Data takes place and our policies are as follows:
(1) We may share your Data with our other group entities in other jurisdictions for internal, business and operational purposes in order to provide the Services. We will ensure, by way of appropriate contractual guarantees which will also be in compliance with applicable laws and regulations, that all such entities with which we share your Data maintain appropriate security measures to protect your Data from unauthorized access or processing and will not share this your Data with any third party unless you expressly agree otherwise.
(2) In order to provide the Services to you, we may need to transfer your Data internationally to non-affiliated entities, which will only occur pursuant to the international transfer mechanisms available under applicable laws and regulations. If the country or region to which your Data is being transferred does not provide an adequate level of protection to your personal data as required by applicable laws and regulations, your Data may be transferred internationally based upon your prior consent, our exercise of a legal right, our compliance with a legal obligation, or the performance of a contract with you, among other mechanisms available under applicable laws and regulations.
8. Data Access and Management
(1) Once you have completed your Account registration and put in place reasonable and necessary authentication measures, you can review, modify, and delete the Data you have submitted to us. In general, you can browse, modify, and delete your own information at any time, but you may not be able to modify certain initial registration information and verification information provided at the time of registration for security and identification purposes.
(2) You may have the following rights to the extent applicable under local laws and regulations which you can exercise by using the contact information provided in this Policy:
(i) You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your Data is processed. You also have the right to obtain confirmation as to whether or not Data concerning you is being processed, and, where that is the case, to access such Data and obtain a copy thereof.
(ii) You have the right to request rectification of your Data. You also have the right to have incomplete Data completed.
(iii) Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your Data to the extent permitted by applicable laws and/or set out in this Policy.
(iv) You may also have other rights as described under the " Country / Region Specific Terms" section below or otherwise under the local laws.
(3) We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required by local laws.
(4) You can change your privacy settings on our app, such as making your account private, disabling the downloading of your posts, and disabling the reading of your clipboard.
(5) You may also be able to change your cookie settings as described in the section below to manage the data we collect using cookies.
(6) You can prevent us from obtaining your Data by suspending certain functions provided by our Services.
(7) You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.
Cookies are pieces of information that any website or app may transfer to your browser that are then stored in your computer or mobile system. For example, the deposit of cookies enhances your online experience by allowing us to save your preferences.
(1) personalize our Services, such as remembering your Data so that you will not have to re-enter it during your use of, or the next time you use, our Services;
(2) provide customized advertisements, content, and information adapted to your profile;
(3) monitor and analyze the effectiveness of our Services and third-party marketing activities adapted to your profile;
(4) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and
(5) track your entries, submissions, and status in any promotions or other activities offered through our Services (services adapted to your profile). Tracking technology also helps us manage and improve the usability of the Services.
We may also collect your shortened IP address on a non-readable basis, which does not allow us to directly identify you.
10. Changes to the Policy
We may update, change or modify the terms hereof from time to time, and such changes shall form a part of this Policy. We will notify you about those changes through general announcements on our Services or by sending a notification to you when you log into or update the app. Unless otherwise indicated, any update, change or modification will become effective on the same day of notification and apply to all of your Data.
11. Parental and Guardian Consent
Anyone under the age of 13 or the minimum age otherwise defined in "Country / Region Specific Terms" under the applicable laws of your jurisdiction (“Minimum Age”) shall not use the Services.
If you have reached the Minimum Age but are under the age of majority as defined under the applicable laws of your jurisdiction (“Majority Age”), you may only use and register a Snack Video account (“Account”) through your parent or legal guardian’s representation, and your parent or legal guardian hereby represents you and accepts this Policy.
If you are a minor in your country or region, your use of the Services may be subject to further age restrictions, whether imposed by us or third-party vendors in connection with the provision of certain Services. You may be unable to use or only have limited access to those Services, such as, where applicable, hosting live streaming, participating in rewards programs, top-up and tipping, without the assistance of your parent or legal guardian.
If you learn that a child under the Minimum Age has registered a Snack Video Account or an Account of a child under the Majority Age was not registered under proper supervision, representation or guardianship, you may alert us at firstname.lastname@example.org. We will promptly investigate, take steps to remove such child’s Account information from Snack Video and terminate the child’s Account.
12. Contact Information
If you have any complaints, suggestions or questions regarding this Policy or in relation to the collection, usage, storage, protection and other functions of your Data, please contact us via the in-app feedback or complaints functions or by email to email@example.com. If a data protection officer is required under the local law of your jurisdiction, you may also contact the data protection officer using the contact details provided in the " Country / Region Specific Terms" section below. We will review the issues involved as soon as possible and reply to you in a timely manner as required by applicable laws. If you have any concerns regarding how we are handling your Data, please contact us. We will endeavor to address your concerns promptly.
(1) Data Security and Protection. In the event that your Data is breached, we will notify you and provide you with detailed information relating to the breach as required under applicable data protection law.
(2) To Whom We May Disclose or Transfer Your Data. You have the option to withdraw your consent to us in disclosing your Data to any third party. In addition, you may request us to wipe out your Data that you have submitted and/or we have collected on our server. If you would like to exercise any of the above rights, please submit your request by sending an email to firstname.lastname@example.org or through other in-app functions if applicable.
(3) Data Storage and Retention. After you have terminated the use of our Service, we will retain your Data for five (5) years (or longer if required under applicable law) as of the date of termination.