Welcome to use Sahran with its available format and versions (hereafter referred to as “ Sahran ”,“we” or “us ”), and become a part of our creative community!

As the operator of Sahran, we respect your right to privacy and highly value the protection of your Personal Data. This Sahran Privacy Policy (“ Privacy Policy ”) explains how we collect, process and protect your Personal Data when you use Sahran and how you can exercise your rights to Personal Data protection. For information that demands your particular notice and that may have a significant impact on your rights and interests, we have highlighted it in bold font to draw your attention. If you do not agree with this policy, you should not access or use the Platform.

“Personal Data” in this Privacy Policy refers any information relating to an identified or identifiable natural person (data subject), including nickname, date of birth, email address, social account information, etc. While we also collect or store other information in a manner that can not be linked back to you ( “Non-Personal Data ”) such as anonymous usage data, landing/exit pages and URLs, platform types, number of clicks, etc.

Sahran has a diverse community of users of various ages. However, in order to protect the privacy and Personal Data of minors, we will obtain parental or legal guardian’s consent where the local laws in your country or region require before processing minors’ Personal Data. Please note, we will limit the types and scope of Personal Data collected from minors as much as possible and also limit the functions available to minors.

If you are a parent or legal guardian of a minor, please ensure that you have read this Privacy Policy and are responsible for your child's activities before allowing your child to create his or her own Sahran account and use the application. You are suggested to pay close attention to your child's use of Sahran and to ensure that your child only uses the age-appropriate functions.

If you have any questions about this Privacy Policy, please contact us using the contact details provided at the end of this Privacy Policy.

This Privacy Policy informs you of the following information:

What types of Personal Data do we collect and our purposes

How do we use cookies and similar technologies

How do we process minor's Personal Data

How do we share and entrust the processing of your Personal Data

How do we protect your Personal Data

How do we store your Personal Data

Your rights

How do we update this Privacy Policy

How to contact us

Governing law and dispute resolution

How will low-quality comments be penalized

Supplemental terms

1. What types of Personal Data do we collect and our purposes

The scope of Personal Data we collect depends on the functions of Sahran you use and how you use these functions. The purposes and types of Personal Data we collect are summarized in the below.

A. The Personal Data you directly provide to us

Registration and Login . If you choose to register for a Sahran account by email or mobile phone number (if applicable), we may need to collect your email address, phone number, nickname, age, gender and a password for your account. If you refuse to provide such Personal Data, you will not be able to complete the registration process and can only use very limited functions of Sahran as a visitor. After you have logged in, you may also choose to add additional Personal Data to your personal profile page, such as your nickname, avatar/portrait, gender, introduction, etc. Users of Sahran may also log in through a third-party platform account (please refer to Section 1.C below for more information).

To further clarify, we may collect the age/birthday provided by users for (i) compliance with laws. By requiring users to provide age/birthday information, Sahran can restrict access to certain features and content that may not be appropriate for minors to comply with laws in different regions, and request consent from the parents to their children's use of Sahran and the process of the minor's Personal Data, and the age/birthday helps identify and address issues related to minors, such as the protection of minors and the prevention of child abuse or delinquent behavior, (ii) account security and authentication. By verifying a user's age/birthday, Sahran can better protect users from fraudulent accounts, unauthorized access, and other security issues, (iii) ad targeting and personalized experience. Sahran uses age/birthday information to better understand the characteristics of its users, to provide a more personalized experience, and to ensure that ads are more accurately delivered to the target user.

Contact and Marketing. We may use the contact information provided by you (e.g., email address) to conduct user survey or to send you information about products and services that may be of interest to you. Where required by applicable laws and regulations, we will obtain your consent before sending you marketing messages. If you are not interested in such information, you may refuse at any time during the communication, for example, by clicking on the unsubscribe/refuse option or sending us a reply to opt-out.

B. The Personal Data provided by you or generated during your use of Sahran

Content Viewing and Other Use. Whether you are viewing a content or using the service after login or as a visitor, we may collect your usage data, including your browsing history and associated network information, and device data, please refer to section “Maintaining Functionality, Stability and Security” for more detail information, so to record and further explore the content you have viewed. For any user viewing publicly available content or using the Service within Sahran without logging in, we will store such usage data we collect with unique identifiers tied to the application and the device you are using, any change to such identifiers may result in you lose the access to your data, so it is advised that you use the service after logging in, so that such data can be stored with your account.

Quick Access to Clipboard. We collect your clipboard when you have copy or paste action with our Platform after we ask for your permission and you choose to allow it. We use such information to enable marketing and promotions, and fulfill the customized user experience. Furthermore, such information will be stored in our App.

Calendar permissions. We request access to your calendar solely to create and manage event reminders for you (e.g., subscription renewals, new episode notifications). You can revoke this permission at any time in your device settings. Upon revocation, we will disable related features and delete all synced calendar data.

Payment and Transaction . When you use our top up or payment functions (including subscription, pay-per-view, purchase, etc.) and initiate a payment request, we need to collect your user ID, country/region, payment currency, payment amount, payment time, payment method, order number and other information to complete the payment and transaction process via the Application Program Interface (API) supported by the third-party payment service providers. In order to prevent money laundering and related illegal activities, we may require you to provide a government-issued ID to verify your identity to comply with relevant legal obligations when you withdraw coins or virtual properties from Sahran. When you use the third party payment service, you may be required to provide your credit/debt card number directly to the third party, the privacy policy of the third party will apply to your data it collected.

Feedback, Report, and Survey. When you use the feedback function within Sahran, we need to collect the feedback description and screenshot. If you do not provide such information, we may not be able to help you resolve the issue or respond to your feedback. In addition, if you wish to make a report (for example, when you discover any illegal content, illegal user activity, or your rights have been violated), we need to collect a description of your report, the type of report, and relevant proofs (if any) in order to understand the facts and help you resolve the issue. When you participate in our survey, we request certain information from you, including Personal Data and Non-Personal Data, and we use such information to optimize our services and provide personalized help and instruction.

Improving User Experience. To improve your user experience (e.g., by making it easier for you to view information about your account, sending you push notifications, and providing you with personalized content and services that may be of interest to you, develop and improve the features, algorithms, and service), we may automatically collect information about your language, gender, clicks and actions, program progress (including login status, interaction information/status, achievement information, etc.), application token, network information (e.g., IP address), device data (including IMEI, IDFA, and other device identifiers, country/region, device model, operating system, screen resolution, anonymous user identifier), approximate geographic location, etc., calculate aggregate statistics number thereof, and analyze such data.

Maintaining Functionality, Stability and Security. In order to maintain the functionality, stability and security of Sahran and your account, we will automatically collect data related to the operation of the mobile application and your online operations, such as application versions, program progress, clicks and actions, device data (e.g., IMEI, IDFA, and other device identifiers, operating system), network information (e.g., IP address), etc. when you are using Sahran.

C. The Personal Data provided by third parties

Third-Party Login. To make it easier to use Sahran applications, you may also choose to register and login within Sahran through your account on a third-party platform (e.g., Google, Meta). In such cases, we may collect your nickname, avatar/portrait, email address, age, gender and third party user identifier and third party token, and by logging in through these third-party accounts, you are consenting to the third-party providing us with the Personal Data concerned. We may also use the contact information (e.g., email address) provided by the third-party platforms to conduct user survey or to send marketing communications to you. Where required by applicable laws and regulations, we will obtain your consent before sending you marketing messages. If you are not interested in such information, you may refuse or opt out at any time.

If you provide us with any Personal Data of any data subjects other than yourself, please bring this Privacy Policy to their attention. You hereby acknowledge that you have obtained their consent or completed other formality as required by other lawful bases for the Personal Data processing in lieu of consent before providing such Personal Data to us. By submitting such information to us, you represent to us that you are entitled to provide and we are entitled to process the relevant Personal Data for the purposes as stated in the Privacy Policy.

In general, we will use your Personal Data only for the purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect the relevant Personal Data. However, we may also process Personal Data for other purposes that are not incompatible with the purposes that we have disclosed to you if and where it is permitted by applicable laws and regulations. If we do so, we will inform you separately by other means to ensure transparency.

2. How do we use cookies and similar technologies

Like many online services, we use cookies and similar technologies to verify log-in information, operate and provide our Services, analyze, and improve user experience. Cookies are usually small text files that are stored on your device's browser directory or program data subfolders for different periods of time. Some cookies are “session cookies”, meaning that they exist only while your browser or the application is open, and will be deleted automatically once you close your browse or application; other coolies are “permanent cookies”, which survive after your browser or application is closed, and can be used by the Service to recognize your device when you open and use the Service again. Cookies allow Sahran to access or store information from your application about you, your settings or your device.

As a rule, cookies do not contain any information that could identify you directly. They do, however, make it possible to offer you a more personalized user experience. You have the right to choose whether or not to accept cookie., Most devices and browsers are initially set up to accept cookies but offer settings to modify cookie preferences. If you do not accept these cookies, you may not be able to use the full functions of Sahran. For example, we use first-party cookies to save your login information for future logins to our service. Such cookies are strictly necessary for the normal operation of Sahran. You can find out more about cookies on allaboutcookies.org .

3. How do we process minors' Personal Data

Sahran is not directed to any minors under the age of 18. If we become aware that any Personal Data has been collected by Sahran from a user under the age of 18 without the consent from the guardian, we will delete such Personal Data and terminate the user's account. If you believe that we have collected Personal Data from a minor under the age of 18, please contact us by using the contact details provided in the “How to contact us” section below.

We recognize that we have a special obligation to protect minors with respect to the collection and processing of Personal Data. We also strongly recommend that parents and guardians educate their children to never disclose or provide any Personal Data about them without your prior permission when using our services. If you have questions on how we process minors’ Personal Data, please contact us using the contact details provided in “How to contact us”.

4. How do we share and entrust the processing of your Personal Data

In order to provide you with better services, we may engage third parties (such as those who assist us in providing services related to Sahran, e.g., cloud service providers, payment service providers) to process your Personal Data on our behalf. We will enter into strict confidentiality contractual terms with such third parties and require them to process Personal Data in accordance with our requirements, this Privacy Policy, and the confidentiality and security measures required by applicable laws and regulations.

We may share your Personal Data with third parties in the following circumstances:

To allow your registering and log in to Sahran using your social network account details (e.g., Facebook/Meta, Google), you will provide us or allow your social network to provide us with your email address and we will likewise share certain information with the relevant social network such as your device data including device identifiers, user name, email address, and network information in this regard.

We provide information and content to service providers who support our business, such as cloud service providers, payment service providers, and analytics providers to ensure that Sahran is a safe and enjoyable place and service providers that assist us in marketing the platform. We may use analysis service such as Firebase and AppsFlyer to collect and share with them the device identifier, and the information about the use of our services such as how often users visit the services, what activities they do, when they visit the services, and what are the locations.

We may share your information with advertisers and third-party measurement companies to show how many and which users have viewed or clicked on an advertisement, or to display personalised advertisements to you.

We may allow third-party ad servers or ad networks to serve advertisements within the platform. These third parties may use technologies like cookies, JavaScript, or web beacons to deliver ads directly to you and to personalize the advertising content you see. When this happens, they automatically receive your IP address to measure ad effectiveness or deliver tailored content. We do not share any personally identifiable information with these third-party ad servers or networks without your explicit consent, except as part of specific programs or features that offer opt-in or opt-out options. We recommend reviewing the respective privacy policies of these third-party ad servers or networks to understand their practices and learn how to opt out of certain activities. Sahran Privacy Policy does not cover and cannot govern the actions of these advertisers or external websites. Any data shared with Sahran by third-party ad servers will be managed according to this Privacy Policy.

We may also share your information with other members, subsidiaries, or affiliates of our corporate group, including to provide, improve and optimise the service of Sahran, to prevent illegal use and to support users.

To detect, prevent or otherwise address security or fraud issues, we may provide your registration information (i.e. your email, cell phone number or the social media token you used to log in the app）, your country/region as selected, and the IP address you last login to the applicable third-party payment service providers during such transactions and payments.

In the event we use information such as user-generated content and video content on our Platform as part of our advertising and marketing campaigns to promote the Platform, your personal data contained in such information may be disclosed to the recipients of such advertising or marketing content.

In the event of any change, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Data, we will ask the new company or organization handling your Personal Data to continue to process your Personal Data in accordance with this Privacy Policy. If the new company or organization handling your Personal Data needs to use your Personal Data for purposes not stated in this Privacy Policy, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.

To relevant competent law enforcement body, regulatory, government agency, court or other third parties where we believe that such disclosure is to (1) comply with an applicable law or regulation; (2) exercise, establish or defend our legal rights; or (3) protect your vital interests or those of any other persons.

5. How do we protect your Personal Data

We use appropriate technical and organizational measures to protect your Personal Data that we collect and process. The measures that we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. For example, we adopt encryption at rest to secure all user data (including database files and backups) and use security keys for data management. We adopt encryption in transit through TLS 1.2 protocols to protect data flow in the public network environment from user devices to servers and from servers to servers. We will also ensure the effective implementation of these technical measures through code review mechanisms. In addition, we periodically test the applications and systems for vulnerabilities and security issues, and take access control measures such as access tokens and multi-factor authentication to ensure information security.

Please be aware and understand that we cannot ensure an absolutely secure Internet. If you find that your Personal Data is breached, please contact us using the contact details provided in “How to contact us” immediately so that we can take the corresponding measures.

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take and other relevant information. In the event of a security incident related to Personal Data, we will report such incident to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem, and take the emergency measures.

6. How do we store your Personal Data

6.1 Cross-border Transfer

We deploy local servers in several countries around the world. For the need of our global operation and security management, your Personal Data may be transferred to and processed in other jurisdictions where our affiliated entities are based in, which may be different from the jurisdiction you locate. Such jurisdictions may not provide the same level of data protection as your jurisdiction. Under such circumstances, we will take necessary and appropriate safeguards to ensure the security of your Personal Data in transit and require that the recipient of your Personal Data offers an adequate level of protection and security in accordance with this Privacy Policy and applicable laws and regulations.

6.2 Retention Period

We will store your Personal Data to the extent as necessary for the proper business needs of our company (e.g., for the purposes of providing service to you and complying with the requirements of laws, tax and finance), except as provided otherwise by applicable laws or regulations. When there is no such need to use your Personal Data or the retention period expires according to applicable laws or regulations, we will delete or anonymize your Personal Data.

7. Your rights

We value the protection of your Personal Data. If you want to access, correct, or delete your Personal Data, or if you want to refuse marketing messages, file a complaint, withdraw consent, or exercise other rights under applicable laws and regulations, please do so as described below or contact us using the contact details provided in “How to contact us”.

7.1 Access your Personal Data

You have the right to access the Personal Data that we collect about you. For Personal Data such as nickname, avatar, email address, and other information that you voluntarily provide to us, you can view them in your personal profile (Setting page) within Sahran; for Personal Data that you provide and generate while using Sahran (e.g., watch history, etc.) as well as Personal Data that third parties provide to us (e.g., third-party platform account information, payment information, etc.), you can access them within the corresponding functions of Sahran. You also have the right to request a copy of your Personal Data from us, by contacting us using the contact details provided in the “How to contact us” section below.

7.2 Correct your Personal Data

We will endeavor to ensure that your Personal Data is accurate and up-to-date by implementing appropriate measures. If your Personal Data is inaccurate or incomplete, you have the right to correct such Personal Data. For Personal Data such as nickname, avatar, and other information that you voluntarily provide to us, you can correct them within your personal profile (Setting page) within Sahran; for Personal Data that you provide and generate while using Sahran (e.g., watch history, etc.) and Personal Data that third parties provide to us (e.g., third-party platform account information, payment information, etc.), if you think such Personal Data needs to be corrected, you can contact us using the contact details provided in the “How to contact us” section below. Please note that for Personal Data provided by third parties, we may not be able to keep the information up-to-date and you may need to contact the third-party for correction.

7.3 Delete your Personal Data

You may delete your Personal Data provided by you in the Profile, if you want to delete all your Personal Data associated with your Sahran account, you can do this on the Setting page (Profile-Setting-Delete account) within Sahran. Please note that after you submit a request to delete your account, you will no longer be able to use Sahran, so please decide carefully. In addition, we will also voluntarily delete your Personal Data after the expiration of the retention period of the Personal Data when the purposes of processing in the first part of this Privacy Policy no longer exist.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Data after termination of services or operations.

7.4 Right to opt-out marketing

You can exercise this right by clicking on the “unsubscribe” or “opt-out” option (or other similar option or link) in the marketing messages we send you.

7.5 Right to file a complaint

You have the right to file a complaint with the data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority. Before you file a complaint, we also sincerely hope that you will first provide us with your comments and we will endeavor to answer your questions and protect your rights.

7.6 Right to withdraw consent

If we process your Personal Data based on your consent, you may withdraw your consent at any time. Please note that withdrawal of your consent will not affect the lawfulness of any processing we have carried out prior to your withdrawal of consent, nor will it affect the lawfulness of our processing of your Personal Data based on a lawful basis other than your consent.

7.7 Other rights under applicable laws and regulations

If you want to exercise your other statutory data subject rights under applicable laws and regulations, you may contact us using the contact details provided in the “How to contact us” section below.

7.8 Identity verification and responding to your requests

In order to protect the security of your information, we may need to verify your identity before responding to your requests to exercise your rights, for example, by requiring you to provide certain identity-related supporting information. We will respond to your request to exercise your data subject rights in accordance with the requirements under applicable laws and regulations and in a timely manner.

8. How do we update this Privacy Policy

We may update this Privacy Policy from time to time in response to the changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. You can see when this Privacy Policy came into effect by checking the “Effective Date” displayed at the top of this Privacy Policy. If you continue to use any functions of Sahran, you are deemed to have read and understood the updated version of the Privacy Policy.

9. How to contact us

If you have any questions or concerns about this Privacy Policy or our processing of your Personal Data, especially if you consider that our processing your Personal Data impairs your legitimate interests, please contact us using the contact details below. We will review your question without delay and make a timely reply according to the applicable laws and regulations. Our contact details are as follows:

Company Name: LITTLE PHONE LLC

Address: 30 N Gould St Ste R Sheridan, WY 82801

Email: contact@sahran.net

10. Governing law and dispute solution

This Privacy Policy is governed by the internal substantive laws of United States of America, without respect to its conflict of law provisions. Any dispute arising out of or in connection with the Privacy Policy, including any question regarding existence, validity or termination of the Privacy Policy, shall be referred to and finally resolved by arbitration administered by a United States of America Arbitration Centre in accordance with the Arbitration Rules for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be in United States of America. The Tribunal shall consist of three (3) arbitrators. The language of the arbitration shall be English.

11.How will low-quality comments be penalized

For sensitive information, violent speech, hate speech, adult content, and other violations in the comments section, we will take measures such as blocking or deleting within 24 hours, depending on the severity. Users who violate the rules will face penalties based on the seriousness of the offense, including but not limited to account muting, suspension, or partial/full service restrictions. We encourage everyone to communicate respectfully and help maintain a positive community environment.

Reporting Process for Violations: If you encounter inappropriate comments, follow these steps to report

Long-press the offending comment.

Click the "Report" button that appears.

Provide specific reasons for reporting. After submission, our team will review and take action promptly.

12. Supplemental terms

(a) India-specific terms

If you are a User in India, the following terms apply to you.

Your Personal Data will be shared or disclosed for the purposes as mentioned in this Privacy Policy and to such third parties only with your consent as provided at the time of registration logging in or payment. To comply with Indian legal requirements, if you are a user in India, we will collect your name, mobile number, email, PAN, address (including state, city, street, and gate number), and zip code when you initiate a payment request. This information will be securely stored upon your first submission to ensure you only need to provide it once. Each time you make a payment, the information will be transmitted to the third-party payment service provider of your choice. Please note that such third parties may further disclose this provided and you hereby consent to such disclosure.

We will not retain any sensitive Personal Data or information for longer than is required for the purpose for which such data or information was collected or may lawfully be used or is otherwise required under any other law for the time being in force. We will retain the Personal Data for a minimum period of 180 days or as required under applicable laws. We may retain anonymized/ de-identified data for as long as is required. However, for the biometric data collected from you (if any), we will not disclose it to any third party and will not use it for any other purpose, and we will delete it within 180 days.

We implement reasonable physical, technical and administrative security standards designed to protect your Personal Data from loss, misuse, alteration, destruction or damage and to ensure a level of security appropriate to the risk and such security standard will be at an equivalent or higher level than the international standard IS/ISO/IEC 27001 on "Information Technology - Security Techniques - Information Security Management System - Requirements".

In respect of cross-border transfer of Personal Data, we will ensure that your Personal Data receives the same or higher level of protection as required under Indian data protection laws.

Our services are not for persons under the age of 18. If you are under 18 years old, you must not use or access the service without the consent of your parent or legal guardian.

In the event of any conflict between the above terms applicable to Users in India and other parts of the Privacy Policy, the India-specific terms shall prevail.

(b) Indonesia-specific terms

If you are a User in Indonesia, the following terms apply to you.

Our services are not for persons under the age of 21. Further, by accessing or using the service, you confirm that you are at least 21 years old. If you are under 21 years old and unmarried, your account must be created under the supervision of your parent or legal guardian and you represent and warrant that you have provided your parent’s or legal guardian’s email address for verification purposes. Your parent or legal guardian will receive a verification email requiring them to approve your account creation. Your account will only be created after your parent or legal guardian clicks on the verification link provided in the email and gives their consent for the creation of an account on your behalf.

You must obtain approval from your parent(s) or legal guardian(s); and your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

In the event we amend the Privacy Policy, we will provide a notification to you regarding the effective date of the changes at the latest fourteen (14) calendar days prior the effective date and may require you to consent to the amended Privacy Policy, through (i) a notice to be posted as pop-up notification or on the flash screen of your mobile device when you access Sahran; or (ii) the contact information you provided to us; or (iii) any other communication methods that are available. If you fail to explicitly express your consent or objection to the amended Privacy Policy within the above advance notification period, you will be considered as accepting the amendments, therefore you will be considered to have agreed to the new Privacy Policy, to the extent permitted by the laws and regulations. However, you may stop using or accessing and uninstall the application of Sahran at any time.

Your Choices. You may withdraw your consent to our disclosure of personal data to third parties. Upon your request, we will ease to display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we may not be able to fulfill your requests and you may not be able to use some of Service features and functionality.

You may request us to (i) disclose history of personal data that we have collected; and/or (ii) erase and dispose your personal data that we have collected on our server. Please note that by requesting us to erase and dispose your personal data, you may not be able to use some of Service features and functionality.

To exercise any of your rights, contact us at Sahransupport@mySahran.com.

Notification. In the event of any breach of personal data, we will notify you and provide you with information regarding such breach of personal data.

Data retention. 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 five (5) years (or longer if required) 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 and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.

In the event of any conflict between the above terms applicable to Users in Indonesia and other parts of the Privacy Policy, the Indonesia-specific terms shall prevail.

If you are a User in Brazil, the following terms apply to you.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that you have read and acknowledged our Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

I. confirmation of whether your data are being processed;

II. access to your data;

III. correction of incomplete, inaccurate or outdated data;

IV. anonymization, blocking or erasure of data;

V. portability of personal data to a third party;

VI. object to the processing of personal data;

VII. information of public and private entities with which we shared data;

VIII. information about the possibility to refuse providing personal data and the respective consequences, when applicable;

IX. withdrawal of your consent.

Verifying your identity: For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to your rights: In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

Contact: In case of doubt about your privacy, your rights or how to exercise them, please contact us through DPO via the contact information below. If you have any questions about the processing of your personal data, we would like to clarify them.

DPO: If you wish to reach the our Data Protection Officer, contact us at: Sahransupport@mySahran.com.

Access Logs. We keep your application access logs, under confidentiality, in a controlled and safe environment, for, at least, 6 months, in order to comply with legal obligations.

In the event of any conflict between the above terms applicable to Users in Brazil and other parts of the Privacy Policy, the Brazil-specific terms shall prevail.

(d) Egypt-specific terms

If you are a User in Egypt, the following terms apply to you.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged our Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

(e) Israel-specific terms

If you are a User in Israel, the following terms apply to you.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged our Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

(f) Mexico-specific terms

If you are a User in Mexico, the following terms apply to you.

Provide you with personalized advertising. We may from time to time provide personalized advertising on our Platform to provide you with a better experience and information that of interest. We offer you the possibility to request reconsideration of such decision by contact us at Sahransupport@mySahran.com.

We use both human and automated means to process your data.

We may share your personal data to a third party for purposes other than processing on behalf of us. We will obtain your consent for such share as required by applicable laws.

By providing us with your personal data and using our Platform you agree to the transfers that require your consent. You can always revoke your consent and exercise your rights, as stated below.

You have the following rights with respect to your personal data: access, rectification, cancelation, opposition, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by sending your request to our email at Sahransupport@mySahran.com. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address. If you are under 18 years, you may exercise your rights through a parent or guardian. Your rights requests will be resolved as soon as possible according to the nature of your request.

Information relating to children. You may review our "How do we process minors’ Personal Data" section in the Terms of Service.

In the event of any conflict between the above terms applicable to Users in Mexico and other parts of the Privacy Policy, the Mexico-specific terms shall prevail.

(g) Philippines-specific terms

If you are a User in Philippines, the following terms shall apply to you pursuant to the relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission ("NPC") on data privacy.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

(h) Russia-specific terms

If you are a User in Russia, the following terms shall apply to you.

What are legal grounds for data processing. When we process your personal data, we rely on your consent, performance of a contract, our legitimate interest and obligations to process personal data, when we so required by law.

By signing up and using the Platform, you consent to the processing of personal data in accordance with this Privacy Policy.

(i) South Africa-specific terms

If you are User in South Africa, the following terms apply to you.

You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged our Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account.

(j) South Korea-specific terms

If you are User in South Korea, the following terms apply to you. In the event of any conflict between the above terms applicable to Users in South Korea and other parts of the Privacy Policy, the South Korea-specific terms shall prevail.

Customized Ads. We may from time to time provide customized ads on our Platform to provide you our Platform for free.

Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable, including, but not limited to:

(i) Act on Consumer Protection in Electronic Commerce Article 6, and Enforcement Degree of the Act on Consumer Protection in Electronic Commerce Article 6

Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years

Records on the handling of consumer complaints or disputes: 3 years

Records on advertisements and labels: 6 months

(ii) Protection of Communications Secrets

Records on your visits to our website: 3 months

Provision of Personal data. We, in principle, does not provide the Personal data to third parties. In order to provide you a smooth and better service, we share information with our business partners service providers entrusted by us. We will enter into strict confidentiality contractual terms with such third parties and require them to process Personal Data within the purpose of process entrusted and in accordance with our requirements (including the retention period which shall be subject to us), this Privacy Policy, and the confidentiality and security measures required by applicable laws and regulations. In addition to the main text of this privacy policy (Section 4 How do we share and entrust the processing of your Personal Data), specifically, we share information with social media including Facebook, Google and Apple if you use them to register Sahran. We entrust cloud service providers such as Amazon Web Service to transmit through their bandwidth service and store your Personal Data in order to provide you with safe and steady services; We will share, to Google Pay, and Apple Pay your commodity information, anonymous user ID, and other payment information as necessary to complete your top-up and purchase in Service.

Destruction of Personal data. We will destroy your personal data without delay when it becomes unnecessary, such as achievement of the purpose of processing your personal data, or the expiration of the retention period. However, this is not the case when preservation is required in accordance with other laws and regulations, such preservation of personal data will be stored separately and will not be used for any other purpose other than as provided by law. The destruction of personal data shall be subject to the approval of the personal data protection officer. We destroy your personal data in electronic form in a manner that renders it unrestorable by the relevant department. In the case of personal data stored in paper, we will destroy your personal data in manner of crushing or burning.

Data rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at Sahransupport@mySahran.com, and we will take action without delay. If you are the legal guardian of a user, you may be able to exercise your data rights on behalf of the user by contacting the aforesaid email address.

Data Security. We work hard to protect us and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data on a need-to-know basis and controlling access to the facilities where personal data is processed.

You declare that you are over the age of 14. If you are under the age of 14, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 14, you hereby declare that you have read and acknowledged our Privacy Policy and Terms of Use and agree to the use by your child of the Platform and registration for an account and the process of Personal Information by us as follows：

For network identification and identifying minor under 14 years old and obtaining consent from parent/legal guardian, we collect and user account ID, password, the date of birth, profile information, email address or social media account information which is used for registration and login, and email address of parent/legal guardian.

For operations and safety, we and AppsFlyer we entrusted collect and use the user behavior data in using our service, account information, device information, service log, and other information that can be shared by platform affiliates and partners with user authorization or in accordance with law, to determine account status, authenticate, detect and prevent security incidents.

Entrustment and/or Overseas Transfer of Personal Data. We entrust, outsource or provide your data to the third parties to conclude and perform the contract with you, or subject to your consents or notifications to you, some of whom may be located abroad (please refer to the Addendum). The entities receiving and processing your data are committed to using and storing personal data in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal data.

You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Service, by contacting us as below. Please note that our online Services rely on the internationalized infrastructure and services of third parties and that cross-border transfers of data to such service providers in the Addendum above mentioned are necessary to facilitate the provision of necessary, convenient and high-quality services to you, so if you refuse the cross-border transfer, the services will not work properly or even have to stop.

Please send your inquiries concerning privacy issues in South Korea to our representative pursuant to the Personal Information Protection Act at Sahransupport@mySahran.com.

(k) Turkey-specific terms

If you are a User in Turkey, the following terms apply to you along with the contents of the foregoing Policy. In the event of any conflict between the terms applicable to Users in Turkey and other parts of the Privacy Policy, the Turkey-specific terms shall prevail.

Data Controller Representative. You may contact our data controller representative at Sahransupport@mySahran.com to handle questions and complaints in connection with the processing of your personal data if you are in Turkey.

Legal bases for the processing your personal data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:

processing is explicitly laid down or dictated by laws

processing of your personal data is necessary provided that it is directly related to the conclusion or fulfilment of the contract between us

processing is mandatory for us to be able to comply with our legal obligations

the relevant data is made available to the public by yourself

processing is mandatory for the establishment, exercise or protection of a right

processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms

your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above)

Your rights. According to Article 11 of the Data Protection Law, you have the following rights with respect to your personal data:

the right to learn whether we process your personal data,

the right to request information with regard to such processing, if we process your personal data,

the right to learn the purposes of the processing and whether they are used for such purpose or not;

the right to know the third parties within or outside the country, to whom we transfer your personal data,

the right to request correction of incomplete or inaccurate personal data,

the right to request deletion or destruction of your personal data under the conditions set forth in Article 7 of the Data Protection Law,

the right to request that we notify the third parties, to whom we transferred your personal data, about the correction, deletion and/or destruction of your personal data per your request within the scope of the foregoing two items,

the right to object to the negative results about you that are due to the analysis of your personal data processed solely by automated means,

the right to claim indemnification for damages incurred due to illegal processing of your personal data.

You may exercise your rights listed above by contact our Data Controller Representative via the contact information listed above.

The requests found in your application will be resolved as soon as possible according to the nature of your request and within thirty days at the latest free of charge. However, if your request incurs additional cost to our company, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

(l) United Arab Emirates-specific terms

If you are a User in the United Arab Emirates ("UAE"), the following terms apply to you. In the event of any conflict between the terms applicable to Users in UAE and other parts of the Privacy Policy, the United Arab Emirates-specific terms shall prevail.

How we share your personal data

In addition to the main text of this policy, by using the Platform in the UAE you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.

Governing law and dispute resolution

By using our Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE. In the event of a dispute arising between the parties in connection with this Privacy Policy:

where the dispute relates to a claim for a sum within the limits specified by the DIFC Small Claims Tribunal from time to time, then the dispute shall be referred by either party to the said Tribunal; and

for all other disputes, the parties shall seek settlement of that dispute by mediation in accordance with the Mediation Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. If the dispute is not settled by mediation within 30 days of the commencement of the mediation, or such further period as the parties shall agree in writing, the dispute shall be referred to and finally resolved by arbitration under the Arbitration Rules of the DIFC-LCIA Arbitration Centre, which Rules are deemed to be incorporated by reference to this clause. The language to be used in the mediation and in the arbitration, shall be English. In any arbitration commenced pursuant to this clause the number of arbitrators shall be one and the arbitration shall be conducted in Dubai.

(m) Vietnam-specific terms

If you are a User in Vietnam, the following terms apply to you. In the event of any conflict between the terms applicable to Users in Vietnam and other parts of the Privacy Policy, the Vietnam-specific terms shall prevail.

Age, Parental and Guardian Consent. By accessing and/or using this Platform, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship, you must obtain approval from your parent(s) or legal guardian(s); an your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

(n) United States of America-specific terms

If you are a User in United States of America, the following terms apply to you along with the contents of the foregoing Policy. In the event of any conflict between the terms applicable to Users in United States of America and other parts of the Privacy Policy, the United States of America-specific terms shall prevail.

Local Representative. You may contact our Local Representative at the following business contact information to handle questions and complaints in connection with the processing of your personal data if you are in United States of America:

Business Contact Address: 30 N Gould St Ste R Sheridan, WY 82801

E-mail address: contact@sahran.net

Legal bases for the processing your personal data. We rely on the following legal bases while processing your personal data in accordance with the Personal Data Protection Act.

Your consent which has been given or is deemed to have given to the collection, use or disclosure of your personal data.

The collection, use or disclosure of your personal data is necessary for any purpose which is clearly in your interests, and consent for the collection, use or disclosure cannot be obtained in a timely way or you would not reasonably be expected to withhold consent.

The collection, use or disclosure of your personal data is necessary to respond to an emergency that threatens your or another individual’s life, health or safety.

The collection, use or disclosure of your personal data is for business improvement purposes.

Processing is explicitly laid down or dictated by laws.

Your rights. According to the Personal Data Protection Act, you have the following rights with respect to your personal data:

the right to learn whether we collect, use or process your personal data,

the right to answer questions with regard to such collection, use or processing,

the right to know the purposes of the collection, use or processing and whether they are used for such purpose or not;

the right to request to provide your personal data that is in the possession or under our control;

the right to request correction an error or omission in the personal data;

the right to withdrawal of consent of your personal data under the conditions set forth in Article 16 of the Personal Data Protection Act;

the right to request that we notify the third parties, to whom we transferred your personal data, about the withdraw of consent of your personal data per your request;

the right to claim indemnification for damages incurred due to illegal processing of your personal data.

You may exercise your rights listed above by contact our Local Representative via the contact information listed above.

Your access request will be processed as soon as reasonably possible and within 30 days at the latest, otherwise we shall inform you in writing when your request will be able to processed.

(o) Japan-specific terms

If you are using our services in Japan, the following additional terms apply:

If you are under the age of 15, please have your parent or legal guardian read this with you. If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under their name, you must cease accessing the Platform.

If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 15, you hereby declare that such user is above the age of 13 and that you have read and acknowledged Sahran's Privacy Policy and Terms of Service and agree to the use by your child of the Platform and registration for an account, as well as Sahran's processing of your child's personal data in accordance with Sahran's Privacy Policy.