diff --git a/app/Privacy/page.tsx b/app/Privacy/page.tsx index d7fac6f..02618e2 100644 --- a/app/Privacy/page.tsx +++ b/app/Privacy/page.tsx @@ -107,6 +107,364 @@ export default function PrivacyPage() {

Where features are available, you may choose to browse certain content in the platform without logging in an account or registering, in which case we may still collect certain Data, including the content you browse, IP address, your interactions with the platform, and associated your device information such as device ID, WiFi information.

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2. How We Use Your Data

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We may use your Data for a number of purposes associated with operating our business and providing the Services to you, including:

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(1) Account Management and Authentication

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We use your Data to verify your identity or eligibility to access the features of Movie Flow, to register your account for the Platform, and to manage and administer your account. In some instances, we may use your Data to verify your age to provide certain Services or to authenticate your identity when fulfilling your requests in relation to your Data.

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(2) Provision of Services

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We process your Data to administer and provide you with the Platform including enabling you to create, edit and modify User Content when you choose to do so, to respond to your queries, or to contact you about changes to Movie Flow and the Platform or any of our Services, and to otherwise manage our relationship with you. This may also include managing the content ecosystem across Movie Flow, facilitating third party partnerships or integrations across Movie Flow, monitoring and testing Movie Flow, troubleshooting, or allowing you and other users to connect with each other.

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(3) Service Improvement and Development

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We inspect and analyze usage information and statistics to maintain and improve Movie Flow and conduct research to develop new product features and technologies aimed at improving the user experience. We understand how you use the Platform, including across your devices, to improve and develop the Platform and conduct product development including adding new features or capabilities, and training and improving our technology, such as our machine learning models and algorithms.

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(4) Payment Processing

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We may use your Data for billing and payment processing purposes or to distribute awards to you or to recover monies owed to us. This may also include enabling payment through third-party payment systems.

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(5) Communications

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We may use your Data to contact and communicate with you, notify you about changes to the Platform, updates to our agreements, terms or policies or providing you with updates related to your access to the Platform in general, and to respond to and process your queries, requests, complaints, and feedback. Communications may include, for example, providing changes or updates about our Services, changes to this Policy, changes to our Terms of Service, user information reports on users who are minors, or responses to your questions, comments, feedbacks or requests.

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(6) Content Safety and Security

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To ensure the safety, security and stability of Movie Flow, we may scan, analyze, and review User Content to detect and combat harmful activity and content, frauds, illegal activity or content on this Platform, if permitted by applicable law.

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(7) Marketing and Promotions

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We may use your Data to build a profile about you, to analyze and understand your preferences, to help determine which marketing materials would be of interest to you, to display advertising, to conduct award activities, to measure the effectiveness of advertising and promotions, and to facilitate sales, purchases and delivery (where applicable). We may also process your Data in the above ways for conducting sweepstakes, contests or other promotions. We may also use your Data to carry out marketing activities, including sending commercial information by electronic means or other marketing activities through various electronic communication channels, including email, text/MMS and push messages.

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(8) Legal Compliance and Rights Protection

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We may use your Data to exercise our rights where it is necessary to do so, for example to detect, prevent, investigate and respond to security incidents or breaches, data scraping, fraud, abuse, intellectual property infringement claims and any other claims, financial crimes, other violations of law, violations of our Terms of Service. We may process your Data to comply with legal or regulatory obligations, codes of practice, guidelines or rules, including our legal obligation to prevent users under the Minimum Age from accessing the Platform or the Services, to respond to lawsuits, claims or investigations, to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority in any instance of mergers, acquisitions, sales and asset transfers, insolvency proceedings, corporate restructuring, winding up or liquidation.

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(9) Unified Account Services

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To provide services to you through related products that are closely connected in functionality. In order to ensure a consistent service experience and to guarantee interconnection between these products, we use a unified account service to collectively collect and process your account information (i.e., nicknames and IDs) across the aforementioned products. The account you register for using this product will also allow you to use a unified account service to log in synchronously, use related products, and access these services.

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(10) Aggregation and Analytics

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We may aggregate and/or de-identify your Data and may use such aggregate or de-identified information for any other purposes to the extent permitted under applicable law and not attempt to re-identify the information, unless required by law.

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+ + {/* Section 3: Our Legal Basis for Processing Data */} +
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3. Our Legal Basis for Processing Data

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In order to process your Data, we will rely upon the legal bases afforded by applicable laws and regulations. We only process your Data when we have a valid "legal basis", including as set forth below:

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(1) Consent

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We may process your Data where you have consented to certain processing of your Data. For example, we may process your Data to use cookies where you have consented to such use.

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(2) Contractual Necessity

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We may process your Data where required to provide you with our Services requested by you, or where necessary for the conclusion or performance of any transaction between you and us. For example, we may need to use or process your Data to respond to your inquiries or requests.

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(3) Compliance with Legal Obligations

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We may process your Data where we have a legal obligation to do so. For example, we may process your Data to comply with tax, labor and accounting obligations.

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(4) Legitimate Interests

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We may process your Data where we or a third party have a legitimate interest in doing so, as recognized in certain jurisdictions. Specifically, we have a legitimate interest in using your Data for product development and internal analytics purposes, as well as to ensure the safety, security and performance of our Services. We only rely on our or a third party's legitimate interests to process your Data when these interests are not overridden by your rights and interests.

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+ + {/* Section 4: Data Storage and Retention */} +
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4. Data Storage and Retention

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(1) Storage Location

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We store your Data on our servers located in Thailand. We also have support, engineering, content moderation, and other functional teams located around the world to support the operation of the Platform and the provision of Services to you. We have rigorous internal control measures in place to strictly limit data access to designated personnel only.

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(2) Retention Periods

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We will retain your Data for as long as necessary:

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  • to achieve the purposes as set out in this Policy;
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  • as required by applicable laws and regulations, including any mandated retention periods, taking into account the statute of limitations;
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  • to serve our legitimate and lawful purposes, including any business, compliance and legal purposes; and/or
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  • to defend against any actual, threatened or potential claims or disputes.
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(3) Data Deletion

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We will not retain your Data for longer than necessary or beyond its intended purposes, unless required or permitted by applicable laws. In addition, we reserve the right to delete, destroy, or anonymize your Data that is no longer needed. We may retain some of your Data even after you cease to use our Services, for instance if the Data is necessary to meet our legal obligations, such as tax and accounting requirements.

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Where applicable, we will delete your Data upon your request unless retention is required by applicable laws. We reserve the right to delete your Data without notice, and we will not owe you any compensation for such deletions.

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If you have questions about the retention periods applied to your Data, you may contact us using the information in the "Contact Information" section of this Policy.

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5. Data Security and Protection

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(1) Security Measures

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We will take appropriate technical and organizational measures to help protect and secure your Data. We will endeavor to protect your Data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:

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  • using encryption techniques;
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  • establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your Data, and requiring those who have such access to comply with relevant confidentiality obligations; and
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  • forming a specialized department in charge of information security.
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In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements.

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(2) Privacy by Default

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We will endeavor to ensure that, by default, we only collect and process your Data needed to provide you access to the Platform and our Services. We also apply this principle of data privacy and protection controls to our processing activities. This means that we will neither publish nor share your Data by default.

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(3) Limitations and User Responsibility

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While we are committed to protecting your Data, no electronic data transmission or storage of information can be completely secure. We kindly request you do not disclose certain Data, such as passwords, credit card numbers, PINs or other confidential data during your use of our Services.

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Our commitment to safeguarding your privacy is unwavering, but the security of Data also relies on your safe practices. Therefore, although we take appropriate technical and organizational measures to secure your Data, we do not guarantee, and you should not expect, that your Data will always remain secure.

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In particular, any email sent to or from us may not be secure. If our email is misused by any third party with malicious intent during the transmission process, you will need to exercise caution. Therefore, please consider carefully what information you choose to send to us via our Services or email.

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In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Services, or third-party websites.

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+ + {/* Section 6: To Whom We May Share Your Data */} +
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6. To Whom We May Share Your Data

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We may share your Data in the following circumstances:

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(1) Affiliates

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We may share your Data with our corporate affiliates, group members, subsidiaries of our corporate group, who will process your Data in accordance with this Policy to facilitate the provision of Movie Flow, to improve the Services, enhance security, and to support users.

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(2) Service Providers and Business Partners

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We may engage service providers and business partners that help us provide, support, and develop the Platform, and understand how it is used. We share your Data with these service providers for purposes such as hosting or operating our Services, storage, content delivery, security, research and development, analytics, customer and technical support, content moderation, payment and transaction processing, advertisement, rewards, vouchers and commercial goods delivery (where applicable), cloud services, email communication, the marketing of our Services to you.

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We may also share your Data with professional agencies and individuals that we engage to provide professional services to us, including advisors, auditors, lawyers and accountants. We will only share your Data on a need-to-know basis with third parties in order for them to perform corresponding functions and services, and we will request such parties to maintain appropriate security measures to protect such Data from unauthorized access or processing.

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(3) Business Transactions

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In the context of a transaction including mergers, acquisitions or asset sales: We may transfer your Data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event or transaction. In order to develop our business, we may engage in transactions such as mergers, acquisitions, sales and asset transfers. In these circumstances, we will inform you of the relevant transactions, and will continue to protect or require the successor to protect your Data in accordance with applicable laws and regulations and this Policy.

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(4) Legal Obligations

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We may in limited cases share your Data to authorities such as legal, regulatory, law enforcement, government and tax authorities or other organizations, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations. We have a good-faith belief that access, use, preservation, or disclosure of such Data is reasonably necessary to:

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  • comply with any applicable law, regulation, or to commence or respond to any legal process/procedure, lawsuit or enforceable governmental request,
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  • protect and defend the rights and property of us, our users, or the public,
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  • detect or prevent technical issues, fraud, or criminal activities,
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  • respond under urgent circumstances to protect the personal safety of any entity, person or group, or
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  • to enforce our Terms of Service and other policies and standards.
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(5) Public Content

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You may submit certain information through Movie Flow (e.g., by uploading photographs, images and videos). Any such information that is meant to be shown to the public on our platform will be disclosed publicly. This Policy does not apply to the use of any such information by third parties after it is uploaded and displayed publicly on Movie Flow.

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Additionally, certain functions of Movie Flow enable you to share information with other users or third-party platforms. Information shared with third-party platforms is subject to their privacy policies. We recommend reviewing those policies to ensure you understand them before sharing any information.

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(6) With Your Consent

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We may share your personal information with third parties with your consent to the disclosure (obtained separately from any contract between us) or at your direction.

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+ + {/* Section 7: International Data Transfers */} +
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7. International Data Transfers

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We may transfer your Data to countries or regions located outside of the country where you reside solely for the purposes set out in this Policy and in accordance with applicable laws and regulations. Such transfers may involve disclosure of your Data to countries and regions that provide varying levels of data protection. Before any cross-border transfer of your data occurs, we consider all relevant legal and regulatory requirements.

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Your personal information may be transferred to, and stored at, a destination outside of your country of residence. We store the information we collect in secure servers located in Thailand. It may also be processed by staff operating outside your country who work for us, one of our suppliers, or one of our business partners.

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We may share your Data with our group entities in other jurisdictions for internal, business and operational purposes in order to operate the Movie Flow and provide you access to the Services. Whenever we transfer personal data to other jurisdictions, we will ensure that such personal data is transferred in accordance with this Policy and as permitted by applicable laws.

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We will ensure, by way of appropriate contractual guarantees which are compliance with applicable laws and regulations, that all such entities with which we share your Data maintain appropriate security measures to protect your Data from unauthorized access or processing.

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+ + {/* Section 8: Your Rights Relating to Your Data */} +
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8. Your Rights Relating to Your Data

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(1) Account Access and Management

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Once you have completed your Account registration and put in place reasonable and necessary authentication measures, you can review, modify, and delete the Data you have submitted to us by contacting us using the contact information provided in the "Contact Information" section of this Policy. In general, you can browse, modify, and delete your own information at any time, but you may not be able to modify certain initial registration information and verification information provided at the time of registration for security and identification purposes.

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You can access and edit your profile information by signing into your account. We also provide tools that allow you to control your information. Should you choose to do so, you may request to delete your account by contacting us via the contact information provided in the "Contact Information" section of this Policy.

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(2) Data Protection Rights

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You may have the following rights to the extent applicable under local laws and regulations which you can exercise by contacting us using the contact information provided in the "Contact Information" section of this Policy:

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  • + Right to Information and Access: You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your Data is processed. You also have the right to obtain confirmation as to whether or not Data concerning you is being processed, and where that is the case, to access such Data and obtain a copy thereof. +
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  • + Right to Rectification: You have the right to request rectification of your Data. You also have the right to have incomplete Data completed. +
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  • + Right to Consent Withdrawal: Where you have provided your consent, you have the right to withdraw your consent. If you withdraw your consent, we may continue processing your Data to the extent permitted by applicable laws and/or set out in this Policy. +
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  • + Right to Data Portability: You have the right to receive your Data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller. +
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  • + Right to Deletion: You have the right to request the deletion or restriction of your Data, as permitted by law. +
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  • + Right to Object: You have the right to object to our processing of your Data, for example, in case we process your data for direct marketing purposes, as permitted under applicable laws. +
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  • + Right to Account Deletion: You have the right to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations. +
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(3) Processing and Response

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We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required or permitted by the local laws. You can change your privacy settings on the website and/or app of Movie Flow, where applicable. You may also be able to change your cookie settings as described in the section below to manage the Data we collect using cookies. You can prevent us from obtaining your Data by suspending certain functions provided by our Services.

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You may exercise the abovementioned rights free of charge by contacting us at the contact details in the "Contact Information" section of this Policy. If requests are manifestly unfounded or excessive, in particular because of the repetitive nature of the requests, we will either charge you a reasonable fee or refuse to comply with the request.

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We will provide you with information about the follow-up to the request without undue delay and in general, within one month of receipt of the request. The applicable privacy laws may allow or require us to refuse your request. If we cannot comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

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These rights are not absolute and they may be limited in some situations. For example, where we can demonstrate that we have a legal requirement to process your data or if making the information available to you would reveal personal data about another person or if we are legally prevented from disclosing such information.

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+ + {/* Section 9: Cookies */} +
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9. Cookies

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Cookies are pieces of information that any website or app may transfer to your browser, which are then stored in your computer or mobile system. For example, the deposit of cookies enhances your online experience by allowing us to save your preferences.

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We use cookies and automatically collected information to:

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  • personalize our Services, such as remembering your Data so that you will not have to re-enter it during your use of, or the next time you use, our Services;
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  • provide customized advertisements, content, and information adapted to your profile;
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  • monitor and analyze the effectiveness of our Services and third-party marketing activities adapted to your profile;
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  • monitor aggregate site usage metrics such as total number of visitors and pages viewed; and
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  • track your entries, submissions, and status in any promotions or other activities offered through our Services.
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Tracking technology also helps us manage and improve the usability across Movie Flow. We may also collect your shortened IP address on a non-readable basis, which does not allow us to directly identify you.

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If you do not want us to collect your Data through the use of cookies, you can set your web browser to reject cookies from Movie Flow. Each browser is different, so you should check your browser's "Help" menu to learn how to change your cookie preferences. Please note that if you reject cookies, you may still use our Services, but your ability to access certain areas of our Services may be limited or restricted.

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+ + {/* Section 10: Third Party Applications and Links */} +
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10. Third Party Applications and Links

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This Policy only applies to our Services. To better enrich your experience, our Service may contain links to other websites not operated or controlled by us (including our affiliates), including payment services. You can choose whether to access such content or links, or whether to use the third party's products or services.

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However, we do not have control over the products or services provided by third parties. Our provision of these links does not imply that we endorse or have reviewed these third-party services. Our Policy does not govern or apply to the data protection issues in connection with your use of any third-party services or websites. We strongly advise you to review the privacy policy of every site you visit.

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If any provisions from this Policy are in conflict with any applicable laws, such provisions will be replaced by provisions of the same purport that reflects the original intention of the provision, to the extent permissible under the applicable laws. In that case, the remaining provisions remain applicable and unchanged.

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11. Changes to This Policy

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We may update, change or modify this Policy from time to time, and such changes shall form a part of this Policy. We will notify you about those changes by updating the "Last Updated" date at the top of the revised Policy, posting the new Policy, and/or providing other notice required by applicable law. We encourage you to periodically review this Policy to stay informed about our current privacy practices.

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Your continued use of the Platform and Movie Flow constitutes acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing the Platform or using Movie Flow.

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12. Parental and Guardian Consent

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Our Services are not intended for or directed to children as defined by the applicable laws in your country or region. In some countries or regions, it refers to individuals under 13 years old ("Minimum Age").

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If you are above the Minimum Age but under the age of majority in your jurisdiction ("Majority Age"), you need your parent or guardian's permission and registration to use our Services. Their consent means they agree to this Policy on your behalf.

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We do not knowingly collect or solicit Data from children under the Minimum Age. If you are a guardian and discover that an individual under your care has used our Services or provided personal Data, please terminate their use of our Services immediately and notify us promptly at the contact details listed in the "Contact Information" section of this Policy so we can take appropriate action. If you wish to query or delete the Data, please contact us through the "Contact Information" section of this Policy.

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Our customer service team may need to verify and confirm the guardianship. Once confirmed, we will assist you in deleting the Data and the corresponding Account as per your request.

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13. Contact Information

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If you have any complaints, suggestions or questions regarding this Policy or in relation to the collection, use, disclosure, storage, protection and other forms of processing of your Data, please contact us:

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  • through email at support@movieflow.ai;
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  • by accessing [Community] in the top navigation bar of the website of Movie Flow;
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If a data protection officer is required to be appointed under the local law of your jurisdiction, you may also contact the data protection officer.

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We will review the issues involved as soon as possible and reply to you in a timely manner as required by applicable laws. If you have any concerns regarding how we are handling your Data, please contact us. We will endeavor to address your concerns promptly.

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If you have any questions, comments and requests regarding this Privacy Policy or about the protection of your personal information, you can contact us via the contact information above. In the event that you wish to make a complaint about how we process your personal information, please contact us 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.

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+ + {/* Final Statement */} +
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+ By using Movie Flow, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. +

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