MiniShorts PP 20231212
Last update: Dec. 2023

Welcome to MiniShorts!
This privacy policy applies to the MiniShorts apps, websites, and related services (the “Platform”). It explains our practices concerning the personal data we collect from you, or that you provide to us, in connection with the Platform. It does not apply to other products or services that display or reference a different privacy policy. If you do not agree with this policy, you should refrain from using the Platform. The Platform is provided and controlled by [NOVENTURE PTE. LTD.], with its registered address at [1 PHENG GECK AVENUE #19 - 22] (“we”or “us”). If you have any questions about how we use your personal data, please contact [].

1. Personal Information We Collect
In order to help you to create an account with the Platform and use the service, we need to collect and process some information. The information we collect depends on how you use the Platform and the choices you make. More information about the categories and sources of information is provided below.
Information you choose to provide
- If you access or use the Platform as a registered user, we may collect your [user id, nickname, age, email address, password and profile photo]. If you choose to use the Platform as a non-registered user, we may collect your age. We collect the age information is for verifying whether you are a qualified user of the Platform.
- If you choose to pay the service on the Platform or withdraw the payment, we may collect [transaction information, such as your payment information, purchase activity and details] (where required for the purpose of payment). This information is required to complete a commercial transaction on the Platform. We use this information to enable and fulfill your transaction.
- If you provide feedback or contact us, or otherwise provide information voluntarily to us, our employees, or our contractors, the data will be collected by us as well.
Information from Third Parties.
You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data. If you connect a social network account to the Platform or choose to register to use the Platform using your social network account details, we will ask permission to access basic information from that account, such as your [username, user id, email address and profile photo], which may depend on your use and settings on the social network.
Information we collect automatically
We automatically collect certain information from you when you use the Platform including when you are using the App without an account. Such information includes:
- Device information. We automatically log your IP address, mobile carrier, time zone settings, device identifiers including [mobile advertising IDs, and the version of the app you are using]. We will also collect information regarding the device you are using to access the Platform such as [the model of your device, the device system, network type, device ID, your screen resolution and operating system].
- Usage data. We automatically log your activity on the Platform, including [the content you view/favourite on the Platform, how long you spent viewing such content, access times, the URL of the website from which you came to our site], and other details about your use of and actions on the Platform.

2. Cookies
We use cookies, mobile IDs, and other similar technologies (e.g. web beacons, Flash cookies, etc.) (“Cookies”) to operate the Platform, enable us to provide certain features and functionality, and enhance your experience using the Platform.
Cookies are small text files placed on your device to store information that can be recalled by the web server in the same domain that placed the cookie. The text in a cookie often consists of a string of numbers and letters that uniquely identifies your device, but it can contain other information as well. Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website. When your browser opens a webpage that contains a web beacon, it automatically connects to the web server that hosts the image (typically hosted by a third-party). This allows that web server to log information about your device and to set and read its own cookies.
We, and our analytics and advertising partners, use Cookies for the following purposes:
- to verify log-in information
- to track traffic flow and patterns of travel in connection with the services
- to understand the total number of visitors to the services on an ongoing basis and the types of devices
- to monitor the performance of the services and continually improve it
- to customize and enhance your online experience
- to provide customer service to you
Most web browsers are set to accept cookies by default. These settings will typically be found in your browser’s Privacy and security menu. You can choose to delete or reject cookies. However, please note that if you choose to delete or reject cookies, this could affect certain features or services of the Platform. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.

3. How We Use Your Information
We use your information to provide the Platform to you and to improve and administer it. We generally use each of the categories of information we collect for the following purposes:
- to create your account of the Platform and provide the Platform services; Identify you across the Platform;
- to measure and understand the effectiveness of the advertising we serve to you and others and to deliver targeted advertising;
- to understand how you use the Platform, including across your devices;
- to infer additional information about you, such as your age, gender, and interests;
- to help us detect abuse, fraud, and illegal activity on the Platform;
- to make age appropriate content available to you;
- to provide customer support and respond to your questions;
- to communicate with you, including to notify you about changes in our services;
- to enforce our terms, conditions, and policies, and to meet our legal obligations;
- consistent with your permissions, to provide you with location-based services, such as advertising and other personalized content;
- for security purposes, other purpose aims to operate, develop and improve the Platform;
- for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
If you choose to use our service or provide your information to us, your information may be transferred to, processed and maintained on servers or databases located outside of the country or jurisdiction where you are located. If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should refrain from using the Platform and our services.

4. How We Share Your Information
We may share your personal data with selected third parties in or outside your country, including:
- our business partners so that we can make you special offers via the Platform;
- service providers or agents that provide services to us for any of the purposes described in this policy, such as cloud storage providers to store the information we collect and for disaster recovery services, as well as for the performance of any contract we entered into with you;
- analytics and advertising providers to help us in the optimisation and improvement of the Platform and to help us serve targeted adverts, as further described in the Cookies section of this policy;
- our subsidiaries, affiliates to provide the Platform including improving and optimising the Platform, preventing illegal use and supporting users.
When you choose to share information to third parties outside of the Platform, the information you share may be able to see and use by third parties. Please note that we may include references or links to products provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, or consent to our sharing personal data with them, that data is governed by their privacy policies.
We may share your information with law enforcement agencies, public or tax authorities or other organizations if legally required to do so. We do not rent or sell your personally identifying information to other companies or individuals, unless we have your consent. We may share aggregated and/or de-identified information in accordance with applicable law.

5. Where We Store Your Personal Data
The information that we collect from you may be transferred to, and stored at, a destination outside of your country. It may also be processed by staff operating outside your country who work for us, for one of our suppliers or one of our business partners. By submitting your information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy and applicable law.

6. Information Security
We take reasonable and appropriate technical and organizational measures to help protect personal data from unauthorized access, use, disclosure, alteration, and destruction. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of your information transmitted via the Platform; any transmission is at your own risk. To help us protect personal data, we request that you use a strong password and never share your password with anyone or use the same password with other sites or accounts.

7. Age Restrictions
This Platform is not directed at children under the age of [17] or equivalent minimum age in the relevant jurisdiction. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [].

8.Your Choices and Rights
You can access and edit most of your profile information by signing into your account. We also provide a number of tools in Settings that allow you to control your information. Should you choose to do so, you may delete your entire account in Settings.
See the Cookies section of this privacy policy for choices about cookies and other analytics and advertising controls. If you have any questions on how to use those tools, or want to know about any rights you may have in the country where you live, please contact us at the email address provided at the bottom of this privacy policy.

9. Data Retention Time and Deletion
We retain your information for as long as it is necessary to provide you with the service or fulfill the transactions you have requested or authorized. 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, including to comply with our legal obligations, enforce our agreements, resolve disputes, and as necessary for the establishment, exercise or defence of legal claims. You have the ability to delete your account, and you should understand that upon deletion of your account, you will lose the right to access or use all or part of the Platform. After you have deleted your account, we may retain certain information in an aggregated and anonymised format.

10. Changes of This Privacy Policy
We will generally notify all users of any material changes to this policy, through a notice provided via the 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 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 Platform.

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 [] and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority or follow the dispute resolution process provided in the Terms of Service.

12. Contact
If you have questions, comments or requests about this policy, you can contact us by mail at: [].