Privacy Policy

1) Scope & Controller

This Policy applies to the App, our websites, and related services (collectively, the “Services”). The data controller is [Company Legal Name], located at [Registered Address]. For users in the EEA/UK, our representative (if applicable) is [EU/UK Representative Name & Address]. Our Data Protection Officer (DPO) can be reached at [dpo@email].

2) Key Definitions

• Personal Data: Information that identifies or can be linked to an identifiable person.
• Processing: Any operation performed on Personal Data (e.g., collection, storage, use, sharing).
• Device Data: Information automatically collected from your phone or tablet when you use the App.

3) Information We Collect

3.1 Information You Provide

• Account & Profile: Name/username, password, email/phone, profile photo, bio, links.
• User Content: Videos, audio, images, captions, livestreams, comments, likes, reports, and associated metadata (e.g., time, location tags you add).
• Direct Messages: Messages, images, and metadata needed to deliver them. We may scan for spam, abuse, or harmful content, as permitted by law.
• Purchases: Transactional details for in‑app purchases, virtual goods, or subscriptions. Payment card data is processed by our payment processors; we receive limited details (e.g., tokens, receipts).
• Customer Support: Information you send us via forms, emails, or in‑app feedback.
• Contacts (optional): If you choose, we may access your contacts to help you find friends. You can revoke this in device settings.

3.2 Information We Collect Automatically

• Usage Data: Actions in the App (views, likes, shares, follows), features used, session length, referral/attribution.
• Device & Log Data: IP address, device identifiers (e.g., IDFA/GAID/AAID where permitted), OS version, app version, language, time zone, crash/diagnostic logs.
• Location: Approximate location from IP; precise location only with your consent.
• Cookies & Similar: Cookies, SDKs, and local storage to operate the App, remember preferences, and measure performance.

3.3 Information From Others

• Other Users who share or interact with your content.
• Partners & Service Providers (analytics, ad networks, anti‑fraud, content moderation).
• Single Sign‑On platforms (if used), which may share your profile and authentication tokens.

4) How We Use Personal Data

• Provide, maintain, and improve the Services (including feed ranking, recommendations, and search).
• Enable social features (follows, comments, DMs, duets/remixes, sharing, live).
• Personalize content and ads where permitted and with your choices.
• Monitor and enforce community guidelines; detect, prevent, and respond to spam, fraud, abuse, IP infringement, and safety risks.
• Communicate with you about updates, security, and support; respond to your requests.
• Measure performance, conduct analytics, debug issues, and develop new features.
• Comply with legal obligations and enforce terms; protect our rights and users.

4.1 Legal Bases (EEA/UK)

• Contract: To provide the Services you request.
• Legitimate Interests: To secure, improve, and market the Services (balanced with your rights).
• Consent: For optional features like precise location, contacts, personalized ads, or push notifications where required. You may withdraw consent at any time.
• Legal Obligation: To meet regulatory or law‑enforcement requirements.

4.2 Automated Decision‑Making

We use algorithms to recommend content and detect harmful activity. Where required by law, you may request human review or object to certain automated decisions affecting you.

5) How We Share Information

• Service Providers & Vendors: Cloud hosting, analytics, content delivery, moderation, customer support, payments, push notifications.
• Partners & SDKs: Ad networks and measurement partners for ad delivery and performance, subject to your choices and applicable law.
• Other Users & Public: Content you post may be viewable according to your privacy settings and the App’s features.
• Legal & Safety: To comply with law, lawful requests, or to protect the rights, safety, and property of users and the public.
• Business Transfers: In connection with mergers, acquisitions, or asset sales.

6) Your Choices

• Manage privacy settings (account visibility, comments, messaging, downloads).
• Opt‑in/opt‑out of personalized ads where available.
• Control permissions (camera, microphone, photos, contacts, location) via device settings.
• Set cookie preferences where offered.
• Unsubscribe from marketing emails using the link in the email.

7) Your Rights

Depending on your location, you may have rights to:

• Access, correct, or delete your personal data.
• Port your data in a structured, commonly used format.
• Object to or restrict certain processing, including profiling for direct marketing.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with a supervisory authority.

To exercise rights, contact us at [privacy@email] or use in‑app tools where available. We may verify your identity before processing your request.

7.1 California (CCPA/CPRA)

• Right to know, delete, correct, and opt‑out of sale/share of personal information and targeted advertising.
• We do not knowingly sell personal information of consumers under 16. To submit a request or opt‑out, email [ccpa@email] or use the “Do Not Sell or Share My Personal Information” link (if available).

7.2 EEA/UK (GDPR)

You may contact our DPO at [dpo@email] and your local supervisory authority. If we rely on legitimate interests, you can object where your rights outweigh ours.

7.3 India

For users in India, you may contact our Grievance Officer (details below) to raise concerns. We process your data in line with applicable Indian law. You may withdraw consent for non‑essential processing at any time via settings where available.

8) Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce agreements. Criteria include account status, content ownership, legal requirements, and system integrity needs. When no longer needed, we take steps to delete or de‑identify data.

9) International Data Transfers

We may transfer, store, and process your information outside your country. Where required, we use appropriate safeguards (e.g., standard contractual clauses) and implement technical and organizational measures to protect your data.

10) Security

We implement administrative, technical, and physical safeguards designed to protect personal data (e.g., encryption in transit, access controls, logging). No system is 100% secure; please use strong passwords and keep them confidential.

11) Children’s Privacy

The Services are not directed to children under the age of [Age Threshold, e.g., 13 or local equivalent]. We do not knowingly collect personal data from children without appropriate consent. If you believe a child has provided personal data to us, contact us to request deletion.

12) Cookies & Tracking

We and our partners use cookies, SDKs, and similar technologies to provide the Services, remember preferences, measure usage, personalize content/ads (where permitted), and improve quality. You can manage cookies in your browser or in‑app settings where available; disabling some may affect functionality.

13) Third‑Party Links & Services

The Services may link to third‑party websites, apps, or services. Their privacy practices are governed by their own policies, not this Policy. Review their policies before providing personal data.

14) User Content & Visibility

When you upload content, it may be visible according to your settings (e.g., public, followers, private). Content may be downloadable or shareable by others, and copies may remain even after deletion if already shared or saved by others, or retained as required by law.

15) Safety, Abuse, and Moderation

We use a combination of human review and automated tools to detect and address violations of our Terms or Community Guidelines. You can report content or users in‑app. We may restrict features, remove content, or suspend accounts that violate our policies.

16) Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by posting the updated Policy in the App and updating the “Last updated” date above, and, where legally required, by additional notice or obtaining consent.