Z Culture Privacy Policy

Welcome to the "Z Culture Platform”, which is provided by PT. SVARA Inovasi Indonesia or one of its affiliates (“Z Culture”, “we” or “us”).

We are committed to protecting and respecting your privacy. This policy explains our practices concerning the personal data we collect from you, or that you provide to us. If you do not agree with this policy, you should not use the Z Culture Platform.

If you have any questions about how we use your personal data, please contact [email protected].

SUMMARY

Collection of member information

We collect and process information you give us when you create an account and upload content to the Z Culture Platform. This includes technical and behavioural information about your use of the Z Culture Platform. We also collect information about you if you download the app and interact with the Z Culture Platform without creating an account.

The use of member information

We use your information to provide the Z Culture Platform to you and to improve and administer it. We use your information to, among other things, show you content suggestions, improve and develop the Z Culture Platform and ensure your safety. Where appropriate, we will also use your personal information to serve you targeted advertising and promote the Z Culture Platform

Sharing of member information

We share your data with third party service providers who help us to deliver the Z Culture Platform, such as cloud storage providers. We also share your information with business partners, other companies in the same group as Z Culture, content moderation services, measurement providers, advertisers, and analytics providers. Where and when required by law, we will also share your information with law enforcement agencies or regulators, and with third parties pursuant to a legally binding court order.

Holding period of member information

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if we believe it is or will be necessary for the establishment, exercise or defence of legal claims.

Notification of Privacy Policy changes

We will generally notify all users of any material changes to this policy through a notice on our Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing or using the Z Culture Platform, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

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1. The Usage of member personal data types

We collect and use the following information about you:

Your Profile Information. You give us information when you register on the Z Culture Platform, including your username, date of birth (where applicable), email address and/or telephone number, information you disclose in your user profile, and your photograph or profile video.

User Content and Behavioural Information. We process the content you generate on the Z Culture Platform, including preferences you set (such as choice of language), photographs and videos you upload and comments you make (“User Content”). In order to improve the upload speed of User Content before clicking “Post” to confirm the upload, we will provide a preload service to upload audio and video in advance. If you cancel or fail to upload the content for other reasons, we will delete the associated audio and video from our server. We collect information through surveys, challenges and competitions in which you participate. We also collect information regarding your use of the Z Culture Platform, e.g., how you engage with the Z Culture Platform, including how you interact with content we show to you, the ads you view, texts you read, audios you listen, videos you watch and problems encountered, the content you like, the content you save to ‘My Library’, users you contact, and the users you follow. We also infer your preferences, including your interests, gender and age for the purpose of personalising content. We process information about your followers, the likes you receive and responses to content you upload, for the purposes of promoting your content to other users and exploring whether your profile presents further opportunities for collaboration. Where appropriate, we will also use this information for the purpose of serving personalised advertising and to tell you about new services and opportunities.

Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Z Culture Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:

If you choose to register to use the Z Culture Platform using 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 username and public profile. We will likewise share certain information with your social network such as your app ID, access token and the referring URL.

We use the information collected from you, and your interaction with the Z Culture Platform and other third party sites, to infer your likely interests to provide you with more relevant advertising. This information tells us about websites you've visited, apps you've downloaded and purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Platform is. We collect this information by the use of Cookies and similar technologies on our App and from similar information received from third parties who advertise on our Platform and whose sites you visit.

Technical Information we collect about you. We automatically collect certain information from you when you use the Z Culture Platform including when you are using the App without an account. Such information includes your IP address, browsing history (i.e. the content you have viewed on the Z Culture Platform), mobile carrier, time zone settings, identifier for advertising purposes and the version of the app you are using. We will also collect information regarding the device you are using to access the Z Culture Platform such as the model of your device, the device system, network type, device ID, your screen resolution and operating system. Where you log-in from multiple devices, we will be able to use your profile information to identify your activity across devices.

Location. We use the 'Region' you select in Settings to customise your Z Culture experience except where we provide location-based services, in which case we collect GPS (where we have your consent).

Find other users and invite your friends. You can choose whether to find other users of the Z Culture Platform using our 'Find Friends' function. This functionality allows you to see which of your friends from either your telephone's contact list or Facebook friends list is using the Z Culture Platform and offers you the option to follow them. You can also use this function to invite your contacts to join you on the Z Culture Platform. We will use the contact information you have for that person, either from within your telephone's contact list or Facebook friends list and give you the option to send them either an SMS, email or third party message (such as Whatsapp, Facebook (including Facebook Messenger) or Twitter) inviting them to view your Z Culture profile.

2. Cookies

We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Z Culture Platform, enhance your experience using the Z Culture Platform, improve our services, and provide you with targeted advertising on the Z Culture Platform and elsewhere across your different devices. Cookies are small files which, when placed on your device, enable the Z Culture Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device. By using the Z Culture Platform, you consent to our use of Cookies.

Additionally, we allow our business partners, advertising networks, and other advertising vendors and service providers (including analytics vendors and service providers) to collect information about your online activities through Cookies. We link your contact or subscriber information with your activity on our Platform across all your devices, using your email or other log-in or device information. These third parties may use this information to display advertisements on our Platform and elsewhere online tailored to your interests, preferences, and characteristics. We are not responsible for the privacy practices of these third parties, and the information practices of these third parties are not covered by this Privacy Policy.

You may be able to refuse or disable Cookies by adjusting your 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 browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Z Culture Platform may no longer be available to you.

3. The usage of member personal data

We will use the information we collect about you in the following ways:

• notify you about changes to our service;
• provide you with user support;
• personalise the content you receive and provide you with tailored content that will be of interest to you;
• enable you to share User Content and interact with other users;
• enable our messenger service to function if you choose to use this function;
• communicate with you;
• to help us detect and combat abuse, harmful activity, fraud, spam, and illegal activity on the Z Culture Platform;
• ensure your safety and security including reviewing user content, messages and associated metadata for breach of our Community Guidelines and other inappropriate content;
• ensure content is presented in the most effective manner for you and your device;
• improve, promote and develop the Z Culture Platform and promote popular topics, hashtags and campaigns on the Z Culture Platform;
• carry out data analysis and test the Z Culture Platform to ensure its stability and security;
• allow you to participate in interactive features of the Z Culture Platform;
• to enable you to socialise on the Z Culture Platform, for example, by allowing other users to identify you via the "Search" function;
• provide you with personalised advertising;
• provide you with location-based services (where those services are available in your jurisdiction);
• enforce our terms, conditions and policies; and
• administer the Z Culture Platform including troubleshooting.

4. Sharing of member personal data

We share your data with the following selected third parties:

If you choose to register to use the Z Culture Platform using your social network account details (e.g., Facebook, Google), you will provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL.

Where you opt to share content on social media platforms, the audio/video/text, username and accompanying text will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared.

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 Z Culture Platform is a safe and enjoyable place.

We use analytics providers to help us in the optimisation and improvement of the Z Culture Platform. Our third party analytics providers also help us serve targeted adverts

We share information with advertisers and third party measurement companies to show how many and which users of the Z Culture Platform have viewed or clicked on an advertisement. We share your device ID with measurement companies so that we can link your activity on the Z Culture Platform with your activity on other websites; we then use this information to show you adverts which may be of interest to you.

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, to provide the Z Culture Platform including improving and optimising the Z Culture Platform, preventing illegal use and supporting users.

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:

• comply with legal obligation, process or request;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• 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).

Please note that if your profile is public, your content will be visible to anyone on the Z Culture 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 an audio/video/text.

We will also disclose your information to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
• 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.

5. Location of member personal data storage

The personal data we collect from you may be stored on a server located in cloud servers, outside of the country where you live. We maintain major servers around the world to bring you our services globally and continuously.

6. Member Content Management

You can access and edit most of your profile information by signing into Z Culture. You can delete the User Generated Content you uploaded. Detailed explanation can be seen on the page User Generated Content

7. Member personal data security

We take steps to ensure that your information is treated securely and in accordance with this policy. Unfortunately, the transmission of information via the internet is not completely secure. Although we will protect your personal data, for example, by encryption, we cannot guarantee the security of your information transmitted via the Z Culture Platform; any transmission is at your own risk.

We have appropriate technical and organizational measures to ensure a level of security appropriate to the risk of varying likelihood and severity for the rights and freedoms of you and other users. We maintain these technical and organizational measures and will amend them from time to time to improve the overall security of our systems.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites.

8. Holding period of personal data

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims.

After you have terminated your use of our Platform, we store your information in an aggregated and anonymised format.

9. Delete your personal data

Our Services give you the ability to delete information about you from within the Service. You can request deletion data from profile settings in edit profile page. You can cancel the requested data deletion by loggin in within 30 days. Data may still remain in the systems back-up files, which will be deleted periodically.

10. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at mailto:[email protected] and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

11. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Z Culture Platform. However, you should look at this policy regularly to check for any changes. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Z Culture Platform after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Z Culture Platform.

12. Contact

Questions, comments and requests regarding this policy should be addressed to [email protected]