Shahla Privacy Policy
This Privacy Policy ("Privacy Policy") describes the privacy practices that we, employ with regard to
collecting, using and disclosing information, both personal and non-personal information, that we receive
when you use our Services. When we say "Services" in this Privacy Policy, we mean the "Services" as defined
in our Terms of Service, accessible at https://www.shahla.live/ and via our mobile device applications. This
Privacy Policy applies only to those websites, services and applications included within "Services" and
doesn't apply to any third-party websites, services, or applications, even if they are accessible through
our Services. By using the Services you consent to the practices described in this Privacy Policy. IF YOU DO
NOT AGREE WITH THE PRACTICES EXPLAINED IN THIS PRIVACY POLICY, DO NOT ACCESS, BROWSE OR USE THE
ShahlaSERVICES.
We are committed to safeguarding any personal information collected through the Services. This Privacy Policy
is intended to inform you of our policies and procedures regarding the collection, use and disclosure of
information on our Services. We also want to inform you about your choices regarding information you share
with us. If you have any questions or concerns, please let us know (see "How to contact us" section
below).
Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same
meanings as in our Terms of Service, accessible at https://www.shahla.live. As used in this Privacy Policy,
the terms "using" and "processing" information include using cookies on a computer, subjecting the
information to statistical or other analysis and using or handling information in any way, including, but
not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and
transferring information within our organization or among our affiliates within the Singapore or
internationally.
How We Collect Info
We collect info in the following ways:
We collect information when you complete your registration to join Shahla and access the Services and/or by
logging into an account that you already have with certain third-party social networking sites ("SNS")
(including, but not limited to, Facebook, Google+, and Twitter) via our Services. For example, our Services
allow you to create an Account and login to the Services using your Facebook account credentials through
Facebook Connect. We collect information that you voluntarily provide to become a registered User of our
Services, and when you use certain aspects of our Services (e.g., entering an email address on a form to
send an email from your Account.)
We collect voluntary information from you, as an Account holder, to add to your Account. This is completely
voluntary on your part and we make every attempt possible to collect as little personally identifiable
information to create these profiles.
When you browse or use our Services, technological tools including "Cookies" collect certain information, as
explained in the following section.
What Information We Collect and How We Use It:
Personal Information:
We collect personally identifiable information ("Personal Information," or "PII") directly from you when you
create an Account. Personal information is information that identifies you and may be used to contact you
either online or offline. Personal Information may include, but is not limited to, your profile photo, stage
name, audio recordings, video recordings, and email address. Additionally, if you register using a valid SNS
account, we use the Personal Information you have already provided to the SNS (such as your "real" name,
email address and other information you make publicly available on the SNS as well as additional information
you've provided specific permission to Shahla to access via the SNS) to create your Account on our Services;
the information we collect may depend on the privacy settings you have with the SNS, so please consult the
SNS's privacy and data practices. For example, by using Facebook Connect, you are allowing Shahla to access
the Personal Information in your Facebook account pursuant to the Facebook Terms of Use regarding your use
of the Services via Facebook. If authorized by you, we may also access your profile and other information
from SNS, like Facebook.
We use your Personal Information (in some cases, in conjunction with your "Non-Identifying Information," see
below) to provide the Services to you. For example:
Account registration:
We create your Account for your use of the Services based upon the Personal Information you provide.
Communications:
We may use your Personal Information to contact you with Shahla newsletters, marketing or promotional
materials and other information that may be of interest to you.
Customer service:
We use your Personal Information to respond to your questions and/or inquiries.
Audio & Video Content
As part of our Services, we collect and store the audio and video recordings that you choose to make within
the Apps while signed into your Account. We do not store or collect audio or video recordings made within
the Apps that are not connected with a valid, signed-in Account. When you save an audio or video recording
on the Services, such audio or video recording is stored on our servers. Audio and video recordings that are
uploaded to the Services are set to "public" by default, which means that anybody using the Services can
view them. You can change your privacy settings to make an audio or video recording "private", in which case
only other Account holders with whom you've shared a link to such audio or video recording will be able to
access it. You can also delete an audio or video recording from your Account on the Services. Deleting an
audio or video recording will prevent anyone (including you) from accessing the audio or video recording;
however, Shahla may retain an archived copy.
Non-Identifying Information
We also collect other information that you provide as part of registration, the operation, and
personalization of your Account that cannot reasonably be used to identify or contact you (e.g., individual
preferences) ("Non-Identifying Information"). Certain Non-Identifying Information would be considered a part
of your Personal Information if it were combined with other identifiers (for example, combining your zip
code with your street address) in a way that enables you to be personally identified or contacted. But the
same pieces of information are considered Non-Identifying Information when they are taken alone or combined
only with other Non-Identifying Information (for example, your viewing preferences).
We may combine your Personal Information with Non-Identifying Information and aggregate it with information
collected from other Shahla users to attempt to provide you with a better experience, to improve the quality
and value of the Services and to analyze and understand how our Services are used. We may also use the
combined information without aggregating it to serve you specifically, for instance to deliver a product to
you according to your preferences or restrictions.
Log Data:
Our servers automatically record certain information about how a person uses our Services, including both
Account holders and non-Account holders ("Log Data"). This Log Data may include information such as the
browser type or the webpage you were visiting before you came to our Services, pages of our Services that
you visit, the time spent on those pages, information you search for on our Services, access times and
dates, and other statistics. We use this information to monitor and analyze use of the Services and the
Services' technical administration, to increase our Services' functionality and user-friendliness, and to
better tailor our Services to our visitors' needs. For example, some of this information is collected so
that when you visit the Services again, it will recognize you and the information could then be used to
serve advertisements and other information appropriate to your interests. We also use this information to
verify that visitors to the Services meet the criteria required to process their requests.
Cookies:
Like many online services, Shahla uses "cookies" on our Services to collect information. A cookie is a small
data file that your browser transfers to your computer. We use cookies for two purposes. First, we utilize
"persistent" cookies to save your login information for future logins to the Services. Second, we utilize
"session ID" cookies to enable certain features of the Services, to better understand how you interact with
the Services and to monitor aggregate usage by Shahla Users and web traffic routing on the Services. Unlike
persistent cookies, session cookies are deleted from your computer when you log off from the Services and
then close your browser.
Google Analytics
We use Google Analytics' Demographics and Interest Reporting feature to collect information about use of
theServices. Google Analytics collects information such as how often users visit the Services, what
activities do they do when they visit the Services, and what are the locations when they login the Services.
You may opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on.
Sharing of your information
Shahla Audio and Video Recordings and Account Information:
When you register through the Services and submit Personal Information to create a profile, this information
will represent you if you choose to share the audio and video recordings you create on the Shahla platform.
Your profile image, stage name, and the audio and video recordings that you have chosen to share, will be
publicly accessible.
Information Shared with Third Parties:
We may share aggregated information that does not include Personal Information and we may otherwise disclose
Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and
other purposes. Any aggregated information shared in these contexts will not contain your Personal
Information. We may also provide your Personal Information to our business partners or other third parties
for the purpose of providing you with information on goods or services we believe will be of interest to
you. Please see our Special Notice to California Residents below.
Service Providers:
We may employ third party companies and individuals to facilitate our Services, to provide the Services on
our behalf, to perform Services-related services (e.g., maintenance services, database management, analytics
and improvement of the Services features) or to assist us in analyzing how our Services are used. These
third parties have access to your Personal Information only to perform these tasks on our behalf.
Social Networking Sites:
We may share the information in your Account (including your Personal Information) with the SNSs that you
have linked to your Account.
Facebook Connect:
You may share your recent activity on our Services back to your Facebook account. You will be prompted to
decide whether or not your activity on the Services will be shared and disclosed on your Facebook service.
We will not otherwise share content, videos, or other Account information to your Facebook account without
your authorization.
Compliance with Laws and Law Enforcement:
Shahla cooperates with government and law enforcement officials and private parties to enforce and comply
with the law. We can disclose any information about you to government or law enforcement officials or
private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and
legal process including, but not limited to, subpoenas, to protect the property and rights of Shahla or a
third party, to protect the safety of the public or any person, to prevent or stop activity we may consider
to be, or to pose a risk of being, illegal, unethical or legally actionable activity, or if it is required
by law.
Business Transfers:
Shahla may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or
all of our assets, including any or all of the information described in this Privacy Policy, in the course
of a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or
any other similar transaction or proceeding.
Your choices regarding information
You have several choices regarding the use of information on our Services:
Your Audio and Video recordings:
You have control over whether to save and upload your audio and video recordings to the Services. We give you
tools to send a link to the audio or video recording that resides on our Services.
Communications:
If you decide at any time that you no longer wish to receive communications from us, please follow the
unsubscribe instructions provided in any of the communications or update your "preferences" information in
your Account settings. As part of providing you the Services, we may need to provide you with certain
notifications and communications, such as service announcements and administrative messages. These
communications are considered part of the Services and your Account, which you may not be able to opt-out
from receiving. If you have any questions about how to unsubscribe communications or update preferences,
please let us know at the contact information provided below.
Cookies:
If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes
described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or
to prompt you before accepting a cookie from the websites you visit. Consult your browser's technical
information. If you do not accept cookies, however, you may not be able to use all portions of the Services
or all functionality of the Services. If you have any questions about how to disable or modify cookies,
please let us know at the contact information provided below.
Additional Information:
We may also use certain additional information from you to help improve and personalized you experience
across our Services. You may choose to share your location with Shahla, or we may determine your location by
using other data from your device, and such location information may help us to precisely provide you
certain features of our services. You will be asked to allow us to collect your location information. If you
decide that you no longer want us to collect your location information, you can go to your device’s setting
page and disable location service for our Services. Also, you may choose to upload and sync your address
book so that we can help you find and connect with users you know or help other users find and connect with
you. You will be given an opportunity to make a choice before you decide to share your address book with us.
You can delete your imported address book contacts at any time by visiting your Account setting in our
Services.
Changing or Deleting Your Information:
All Account holders may review, update, correct or delete the Personal Information in their Account by
contacting us or by editing their profile via the Services. With respect to recordings made through the
Services: You can change your privacy settings to make an audio or video recording "private", in which case
only other Account holders with whom you've shared a link to such audio or video recording will be able to
access it. Account holders can also delete an audio or video recording from the Services, which will prevent
anyone (including you) from accessing the audio or video recording; however, Shahla may retain an archived
copy on its servers.
How we store and protect information
Information Security:
We care about the security of your information. We use commercially reasonable safeguards to preserve the
integrity and security of information collected and maintained through the Services. However, we cannot
ensure or warrant the security of any information you provide to us or guarantee that information on the
Services may not be accessed, disclosed, altered, or destroyed by unauthorized persons.
Phishing:
Identity theft and the practice currently known as "phishing" are of great concern to Shahla. Safeguarding
information to help protect you from identity theft is a top priority. We do not request your credit card
information, login information, or national identification numbers in a non-secure or unsolicited e-mail or
telephone communication.
Breach Notification:
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of
stored "personal data" (as defined in applicable state statutes on security breach notification) to you via
email or conspicuous posting on the Services in the most expedient time possible and without unreasonable
delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary
to determine the scope of the breach and restore the reasonable integrity of the data system.
International Transfer:
Your information may be transferred to - and maintained on - computers located outside of your state,
province, country or other governmental jurisdiction where the privacy laws may not be as protective as
those in your jurisdiction. If you are located outside the Singapore and choose to provide information to
us, Shahla transfers Personal Information to the Singapore and processes it there. Your consent to this
Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Do Not Track Disclosures
Our Services are not set up to respond to Do Not Track ("DNT") signals. We use third party service providers
like Google Analytics for tracking purposes.
Special Notice to California Residents
California Shine the Light Law: California residents may request a list of all third parties to which we have
disclosed certain Personal Information about you for marketing purposes. You may make one request per
calendar year. In your request, please attest to the fact that you are a California resident and provide a
current California address for your response. You may request this information in writing by contacting us
at:services@shahla.live. Please allow up to thirty (30) days for a response.
California Minors: If you are a California resident under age 18 and you are unable to remove
publicly-available information that you have submitted to Shahla, you may request removal by contacting
Shahla at: services@shahla.live. When requesting removal, you must be specific about the information you want
removed and provide Shahla with specific information, such as the URL for each page where the information is
located, so that we can find it. Shahla is not required to remove any information that: (i) law requires us
or a third party to maintain; (ii) was not posted by you; (iii) Shahla anonymizes, so that you cannot be
identified; (iv) you don't follow our instructions for removing or requesting removal; or (v) you received
compensation or other consideration for providing the information. REMOVAL OF YOUR INFORMATION FROM THE
SERVICES DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT INFORMATION FROM OUR SYSTEMS OR THE
SYSTEMS OF OUR SERVICE PROVIDERS. Shahla is not required to delete the information; Shahla' obligations
under California law are satisfied so long as we anonymize the information or render it invisible to other
users and the public.
Links to Other Sites
Our Services may contain links to other websites and services. Any information that you provide on or to a
third-party website or service is provided directly to the owner of the website or service and is subject to
that party's privacy policy. Our Privacy Policy does not apply to such websites or services and we're not
responsible for the content, privacy or security practices and policies of those websites or services. To
protect your information we recommend that you carefully review the privacy policies of other websites and
services that you access.
Credit card payments, including recurring charges such as charges for subscriptions to the Service, are
handled through Apple and Google, or other third party payment processors. Apple and Google will collect and
may retain your credit card information in order to process your payment, including payment for your
purchases of subscriptions or for any Service charges. We do not control this third party collection, use,
disclosure, or retention of your information. Please review Apple's and Google's privacy policy and terms of
use prior to submitting your payment information.
Our Policy Toward Children:
Our Services are NOT directed to children under 13, and we do not knowingly collect PII from children under
13. We take extra steps to ensure that users creating Accounts are 13 or older. If we learn that we have
collected PII of a child under 13, we will take steps to delete such information from our files as soon as
possible. We encourage parents to take precautions to assure that their household is safe and protected when
creating and sharing this video content.
Changes
Any information that is collected is subject to the Privacy Policy in effect at the time such information is
collected. We may, however, modify and revise our Privacy Policy from time-to-time. If we make any material
changes to this policy, we will notify you of such changes by posting a new Privacy Policy and updating the
"last modified" date at the top of this page or by sending you an email or other notification, and we will
indicate when such changes will become effective. By continuing to access or use the Services after those
changes become effective, you are agreeing to be bound by the revised policy.
Reporting and Blocking
In order to ensure that Shahla is safe and trusted platform, we have developed a standards to define and
prohibit content which is harmful or inappropriate to our users. You must accept our agreement when
uploading and producing content. We provide an easy-to-use reporting system in the APP to accept users'
reports on your content, and we also provide a blocking system you are allow to block offensive content in
the first time. After receiving the user's report,our staff will follow up the user's report as soon as
possible. We have the right to delete or prevent abusive users whom violate the terms of use of the
application and/or user policies without notifying the user in advance.
The production and dissemination of the following content will be defined by us as objectionable and
inappropriate content. Users can block the following content. After receiving the report, we will verify
that the content is inappropriate or not. We will remove or block the content producers.
Pornography and profanity
We are not allow the inclusion or promotion of pornographic or profane content. Including content that
include some pronographic inside, or any content nor services designed to provide sexual satisfaction. It is
strictly forbidden to play sexual, life-threatening performances or pornographic videos. It is strictly
forbidden to display sensitive parts of the body with sexual characteristics in various ways, such as
touching sensitive parts, displaying female breasts, male and female buttocks and inner thighs; using and
Promote any sexual stuffs.
Hate speech and national security
We are not allow the promotion of violence or incitement of systemic discrimination or marginalization of
hatred against individuals or groups based on race or ethnicity, religion, disability, age, national origin,
veteran status, sexual orientation, gender, identity or any other related topic. We also not allow content
that directly related to national security and national defense security to appear on our platform.
Violence
We are not allow portraying or facilitating unprovoked violence or other dangerous activities. We are not
allow content related to terrorism, such as content that promotes terrorist acts, incites violence, or
celebrates terrorist attacks. If you post terrorism-related content for educational, documentary,
scientific, or artistic purposes, please be careful to provide enough information so that users can
understand the context.
Sensitive events
We are not allow unreasonable sensitivity to natural disasters, atrocities, health crises, conflicts, deaths,
or other tragic events, or using an events to arouse users’ sympathy. At the same time, we also strictly
prohibit the spread of terrorism, extremism, war-promoting speech, violates religious freedom speech and
provoke events.
Bullying and harassment
We are not allow content that contains or contributes to threats, harassment or bullying, including
infringing on the privacy of others, endangering the safety of others, endangering the public interest,
infringing on others, cruelty to animals, etc.
Gambling
Such as live gambling, content that incites others to do gambling are not allow.
Dangerous stuffs and other content that related to local laws and regulations
We are not allow content such as guns, ammunition, alcohol, marijuana, etc.,all stuff that not legal in your
country. We also not allow a behavior that count as violates action in country you stay , even if the
behavior is legal in other countries.
Content under 14 years old
We are not allow young people under the age of 14 to use our APP, due we do allow some content that not
suitable for people under age. Including to promotion of pedophilia or inappropriate interaction with
minors, such as groping or caressing.
Damage to the interests of the platform
Any behavior that harms the interests of the platform will be defined as inappropriate content by us,
including deceivies the user by pretending to be the staff of out platform.
Child Safety
We are committed to protecting the safety of children and preventing any form of sexual abuse, sexual
exploitation and related harmful behaviors. Our applications comply with all applicable laws and regulations
as well as the "Child Safety Standards" policy, and always put the safety and rights of children first.
Scope of application
This standard applies to all users and related content, including but not limited to user-generated content,
interactive behaviors, reporting mechanisms and content review. Our goal is to create a safe and inclusive
social environment, especially providing additional protection for underage users.
Core measures
Strict age restrictions:
We require users to confirm their age when registering, and take additional protection measures for minors,
including restricting access to certain features.
Content review:
All user-generated content (UGC) is double-reviewed by humans and algorithms to prevent any content
containing sexual abuse, sexual exploitation or inappropriate behavior from appearing on the platform.
User Code of Conduct:
Any sexualized behavior, language or other forms of inappropriate behavior involving children on the
platform is prohibited. Once discovered, it will be dealt with immediately and reported to the relevant
authorities.
Reporting and response mechanism:
Provide user-friendly reporting tools so that any user can quickly report suspicious content or behavior.
Our dedicated team will handle related issues within 24 hours of receiving the report.
Cooperation and reporting:
We cooperate with child protection organizations and law enforcement agencies to ensure timely investigation
and reporting of all suspected cases of sexual abuse and sexual exploitation.
Accountability and transparency
We regularly update and publicize policies and measures related to child protection, and disclose our
implementation and improvement plans to users through annual transparency reports.
Contact us
If you find content or behavior involving child sexual abuse or sexual exploitation, please contact us in
the following ways:
Online reporting tools: "Feedback" and "Report" functions in the application