WHAT KINDS OF INFORMATION
DO WE COLLECT?

1.1. Your Profile Information: You give us information when you register on the Platform, including your username, password, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video. It can also include what you see through features that we provide, such as our camera, so we can do things such as suggest masks and filters that you might like, or give you tips on using camera formats.

1.2. User Content: We process the content you generate on the Platform, including photographs, audios and videos you upload or create, comments, hashtags, feedback, reviews, and livestreams you make, and the associated metadata, such as when, where, and by whom the content was created (“User Content”). Even if you are not a user, information about you may appear in User Content created or published by other users on the Platform. We collect User Content through pre-loading at the time of creation, import, or upload, regardless of whether you choose to save or upload that User Content, in order to recommend audio options and provide other personalized recommendations. If you apply an effect to your User Content, we may collect a version of your User Content that does not include the effect. We may access content, including text, images, and video, found in your device’s clipboard, with your permission.

1.3. Messages: We collect information you provide when you compose, send, or receive messages through the Platform’s messaging functionalities. They include messages you send or receive through our chat functionality from other users on the Platform. That information includes the content of the message and information about the message, such as when it was sent, received, or read, and the message participants. Please be aware that messages you choose to send to other users of the Platform will be accessible by those users and that we are not responsible for the manner in which those users use or share the messages. The Platform will not be held liable or responsible for any content shared in any messages.

1.4. Networks and Connections: We collect information about the people, accounts, hashtags, ads that you are connected to and how you interact with them across our Platform. We also collect contact information if you choose to upload, sync or import it from a device (such as an address book or call log or SMS log history), which we use for things such as helping you and others find people you may know and for the other purposes listed below.

1.5. Your Usage: We collect information about how you use our Platform, such as the types of content that you view or engage with, the features you use, the actions you take, the people or accounts you interact with and the time, frequency and duration of your activities. For example, we log when you're using and have last used our Platform, and what posts, videos and other content you view on our Products. We also collect information about how you use features such as our camera.

1.6. Purchase Information: When you access or redeem your Coins from the wallet (“Wallet”) or any other financial transactions as may be available on the Platform, we may collect information about the payment transaction, such as payment card information, billing, contact information, and any other account and authentication information.

1.7. Things others do and information they provide about you: We also receive and analyse content, communications and information that other people provide when they use our Platform. This can include information about you, such as when others share or comment on a photo of you, send a message to you or upload, sync or import your contact information.

1.8. Proof of your identity or age: We sometimes ask you to provide proof of identity or age in order to use the Platform and for certain features on the Platform, or when you setup the Wallet, to ensure that you are old enough to use the Platform, or in other instances where verification may be required.

1.9. Information in correspondence you send to us, including when you contact us for support or feedback.

1.10. Information through surveys, research, promotion, contests, marketing campaigns, challenges, competitions or events conducted or sponsored by us, in which you participate.

AUTOMATICALLY COLLECTED INFORMATION

2.1. Usage Information: We collect information regarding your use of the Platform, e.g., how you engage with the Platform, including how you interact with content we show to you, the advertisements you view, videos you watch and problems encountered, browsing and search history, the content you like, the content you save, the users you follow and how you engage with mutual followers.

2.2. Inferred Information: We also infer your attributes, including your interests, gender and age range for the purpose of personalising content.

2.3. Technical Information we collect about you: We collect certain information about the device you use to access the Platform, such as your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, device IDs, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices. We may also associate you with information collected from devices other than those you use to log-in to the Platform.

2.4.Location Information: We collect information about your approximate location, including location information based on your SIM card and/or IP address. With your permission, we may also collect precise location data (such as GPS). In addition, we collect location information (such as tourist attractions, shops, or other points of interest) if you choose to add location information to your User Content.

2.5. Image and Audio Information: We may collect information about the videos, images, audio and live streams that are a part of your User Content, such as identifying the objects and scenery that appear, the existence and location, within an image, of face and body features and attributes, the nature of the audio, and the text of the words spoken in your User Content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations.

COOKIES

Our Platform uses cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you browse our website and when you use our app and allows us to improve our site. Cookies are small pieces of text used to store information in web browsers (if you consent). Cookies contain information that is transferred to the hard drive of your device.

3.1. Authentication
We use Cookies to verify your account and determine when you're logged in so that we can make it easier for you to access the Platform and show you the appropriate experience and features.

3.2. Security, Site and Integrity
i. We use Cookies to help us keep your account, data and the Platform, safe and secure.
ii. Cookies can help us identify and impose additional security measures when someone may be attempting to access an account on the Platform without authorisation, for instance, by rapidly guessing different passwords.
iii. We also use Cookies to combat activity that violates our policies.

3.3. Advertising, Recommendations, Insights and Measurement
i. We use Cookies to help us show ads and to make recommendations for businesses and other organisations to people who may be interested in the products, services or causes they promote.
ii. We also use Cookies to help measure the performance of ad campaigns for businesses that use the Platform.
iii. Cookies help us serve and measure ads across different browsers and devices used by the same person. iv. Cookies also allow us to provide insights about the people who use the Platform, as well as the people who interact with the ads, websites and apps of our advertisers and the businesses that use the Platform.

3.4. Site Features and Services
i. We use Cookies to enable the functionality that helps us provide the features on the Platform. Cookies help us store preferences, know when you've seen or interacted with Platforms’ content and provide you with customised content and experiences.
ii. We also use Cookies to help provide you with content relevant to your locale.

3.5. Performance We use Cookies to provide you with the best experience possible.

3.6. Analytics and Research We use Cookies to better understand how people use the Platform so that we can improve them.

3.7. Third Party
Please note that when you access or use our services through third-party websites, we may share some information with them when you perform certain actions in the purchase flow. We will not use any Cookies or pixels for these purposes. We may not be able to erase your data in new sessions if there is no way for us to identify you. They serve the same purposes as Cookies set in the Platform, which are to personalise content (including ads), measure ads, produce analytics and provide a safer experience, as set out in this Policy.

INFORMATION FROM OTHER SOURCES

4.1. We may receive the information described in this Policy from other sources, such as:

4.2. If you choose to integrate a third-party social network account details (e.g., Facebook, Twitter, Instagram, Google etc.) or login service, you will provide us or allow to provide us with your username, public profile, and other possible information related to such account. We may share certain information with your social network such as your app ID, access token and the referring URL. If you link your Ginni Social account to another service, we may receive information about your use of that service.

4.3. Advertisers, measurement and other partners share information with us about you and the actions you have taken outside of the Platform, such as your activities on other websites and apps or in stores, including the products or services you purchased, online or in person. These partners also share information with us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help match you and your actions outside of the Platform with your Ginni Social account.

4.4. We may receive information about you from others, including where you are included or mentioned in User Content, direct messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us. We may collect information about you from other publicly available sources.

HOW DO WE USE THIS INFORMATION?

We use your information to improve, support and administer the Platform, to allow you to use its functionalities, and to fulfil and enforce our Terms. We generally use the information we collect in the following ways:

i. To fulfil requests for services, Platform functionality, support and information for internal operations, including troubleshooting, data analysis, testing, research, statistical, and survey purposes and to solicit your feedback.

ii. To personalise the content you see when you use the Platform.

iii. To send promotional materials, including by instant messaging or email, from us or on behalf of our affiliates and trusted third parties.

iv. To improve and develop our Platform and conduct product development.

v. To measure and understand the effectiveness of the advertisements and other content we serve to you and others, and to deliver advertising, including targeted advertising, to you on the Platform.

vi. To support the social functions of the Platform, including to permit you and others to connect with each other and to share whether you are active on the Platform with your friends, to provide our messaging service if you choose to use this function, to suggest accounts to you and others, and for you and others to share, download, and otherwise interact with User Content posted through the Platform.

vii. To use User Content as part of our advertising and marketing campaigns to promote the Platform, to invite you to participate in an event, and to promote popular topics, hashtags and campaigns on the Platform.

viii. To understand how you use the Platform, including across your devices.

ix. To infer additional information about you, such as your age range, gender, and interests.

x. To help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Platform.

xi. To ensure content is presented in the most effective manner for you and your device.

xii. To promote the safety, security of the Platform, including by scanning, analyzing, and reviewing User Content, messages and associated metadata for violations of our Terms, Community Guidelines, or other conditions and policies.

xiii. To facilitate research conducted by independent researchers that meets certain criteria.

xiv. To verify your identity or age.

xv. To communicate with you, including to notify you about changes in our services.

xvi. To announce you as a winner of our contests or promotions if permitted by the promotion rule, and to send you any applicable prizes.

xvii. To enforce our Terms, Community Guidelines, and other conditions and policies.

xviii. Consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content.

xix. To train and improve our technology, such as our machine learning models and algorithms.

xx. To facilitate and fulfil sales, promotion, and purchases of goods and services and to provide user support.

HOW IS THIS INFORMATION SHARED?

We share your information with the following parties:

6.1. Business Partners
i. If you choose to integrate your social network account details (e.g., Facebook, Twitter, Instagram, Google), you will provide us or allow your social network to provide us with your phone number, email address, username and public profile. We may share certain information with the relevant social network such as your app ID, access token and the referring URL. If you choose to allow a third-party service to access your account, we will share certain information about you with the third party. Depending on the permissions you grant, the third party may be able to obtain your account information and other information which you choose to provide.
ii. Where you opt to share content on social media platforms, the video, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms, a link to the content will be shared.

6.2. Music Labels
By virtue of the Platform being a short-video platform, we have entered into music license agreements with various music labels in order to ensure optimal user experience on the Platform. Information pertaining to music data might be shared with such music labels from time to time in an anonymized manner.

6.3. Service Providers
We provide information and content to service providers who support our business, such as cloud service providers and providers of content moderation services, to ensure that the Platform is a safe and enjoyable place, and service providers that assist us in marketing the Platform.

6.4. Payment Processors and Transaction Fulfilment Providers:
You get paid in Ginni Social currency called “Coins” which is credited to your Wallet. If you choose to redeem or withdraw your Coins or conduct other payment related transactions, we will share data with the relevant payment provider to facilitate this transaction.

6.5. Analytics Providers: We use analytics providers to help us in the optimisation and improvement of the Platform. Our third-party analytics providers also help us serve targeted advertisements.

6.6. Advertisers, Advertising Networks and Measurement Partners
i. We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement.
ii. We provide aggregated statistics and insights that help people and businesses understand how people are engaging with their posts, listings, ads and User Content.

6.7. Independent Researchers: We share your information with independent researchers to facilitate research that meets certain criteria.

6.8. Our Corporate Group: We may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide the Platform, to improve and optimise the Platform, to prevent illegal use and to support users.

6.9. For Legal Reasons We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if such use is reasonably necessary to:
(i) comply with legal obligation, process or request;
(ii) enforce our Terms and other agreements, policies, and standards, including investigation of any potential violation thereof;
(iii)detect, prevent or otherwise address security, fraud or technical issues; or
(iv)protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

6.10. Public Profiles Please note that if your profile is public, your content will be visible to anyone on the Platform and may also be accessed or shared by your friends and followers as well as third parties such as search engines, content aggregators and news sites. You can change who can see a video each time you upload a video. Alternatively, you can change your profile to default private by changing your settings.

6.11. Third Parties
i. We may integrate with other third party products and services to enable certain features of the Platform. We do not share your personal information with them except as is necessary in order to allow them to perform the features requiring their integration.
ii. if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

6.12. Merchants, Payment and Transaction Fulfilment Providers, and Other Service Providers
When you withdraw or redeem your Coins through the Wallet, we share the information related to the transaction with the merchant, payment and transaction fulfilment providers, and other service providers.

YOUR RIGHTS AND CHOICES

7.1. You have rights and choices when it comes to your information. You may be afforded certain rights under applicable laws, which may include the right to access, delete, update, or rectify your data, to be informed of the processing of your data, to file complaints with authorities, and potentially other rights. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

7.2. You can access and edit most of your profile information by signing into Ginni Social. You can delete the User Content you uploaded. We also provide a number of tools in Settings that allow you to control, among others, who can view your videos, send you messages, or post comments to your videos. Should you choose to do so, you may delete your entire account in the Platform settings.

7.3. You may be able to refuse or disable Cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of the browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Platform may no longer be available to you

SECURITY AND INTERNATIONAL TRANSFERS OF DATA

8.1. Your information may be stored on servers located outside the country you reside in. We maintain major servers around the world to bring you our services globally and continuously.

8.2. We are committed to ensuring that your information will be treated confidentially and securely, and we have put in place appropriate measures to ensure the security of your personal data.

8.3. The personal data that we collect from you may be transferred to, and stored at, destinations outside the country you reside in, where the laws on processing personal data may be less stringent than in your country. It may also be processed by staff operating outside the country you reside in, who work for us or for one of our agents or suppliers.

8.4. Presently, personal data collected from you is stored in data centres as well as cloud networks. Please feel free to contact support@ginnisocial.com for more information.

8.5. When your personal data is transferred to parties located outside the country you reside in, we will assess and take appropriate measures to ensure these third parties provide adequate security of such personal data and respect your rights to privacy. Notwithstanding, you acknowledge that some overseas third parties may not be regulated by the applicable laws and if any third party engages in any act or practice that contravenes the applicable law, it would not be accountable under the applicable law and you will not be able to seek redressal under the applicable law.

8.6. If you would like any more information on the safeguards used, feel free to contact us at support@ginnisocial.com.

DISCLAIMER

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to the Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

DATA RETENTION

10.1. We may hold on to your personal data for as long as we need to for the purposes for which it is processed or as is otherwise required by applicable law. If you terminate your account on the app and/or website, stop using the Platform, or our agreement with you under the Terms is terminated, we will delete your information as it is no longer relevant, but we might need to continue to process your personal data as required under applicable law, in order to establish, exercise or defend legal claims where relevant.

10.2. We calculate the appropriate retention period for your data by considering the nature and sensitivity of the data, the purposes for which we are processing the data, and any applicable statutory retention periods. Using these criteria, we regularly review the personal data which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete or anonymise your personal data.

10.3. We may delete your account or specific information before deactivating your account if we believe it may no longer be relevant, or where an account has been inactive for more than a year.

INFORMATION RELATING TO CHILDREN AND TEENS

Ginni Social is not directed at children under the age of 13. In certain cases this age may be higher due to local regulatory requirements. If you believe that there is a user who is below this minimum age, please contact us at support@ginnisocial.com

LINKS FROM OUR WEBSITE

We may have pages containing external links. You are advised to verify the privacy practices of such externally linked websites. Ginni is not responsible for the manner of use or misuse of information made available by you at such other websites. We encourage you not to provide personal information, without assuring yourselves of the privacy policy of external linked websites.

CONTACT AND COMPLAINTS

If you have any complaints about how we handle your personal information, please contact us at support@ginnisocial.com . If we are unable to resolve your complaint and you wish to take your complaint further, you can do so by contacting the Grievance Officer.

In accordance with the prevalent act and rules, the name and contact details of the Grievance Officer are provided below:

Name: Ashish Kumar Singh
Address: Oonzoo Portal LLC, 1401, Al Moosa tower 2, Sheikh Zayed Road, Dubai
Email: ashish@oonzoo.ae
Phone: +971555828736