Privacy Policy

Last Updated: [November 3, 2025]

1. Introduction

This Privacy Policy applies to the Zapclip application (hereinafter referred to as "Zapclip" or the "Platform"). The independent developer, febby triandanawari (hereinafter referred to as "we" or the "Developer"), will fulfill privacy protection obligations in accordance with relevant Google Play Store rules and applicable laws.

We respect and are committed to protecting your privacy. This Policy details how we collect, use, share, and protect personal information generated during your use of our services. This Policy is globally applicable; supplementary provisions for specific jurisdictions can be found in "Section 13 - Supplemental Terms - Specific Jurisdictions". If you do not agree with this Policy, please do not use Zapclip. We recommend that you carefully read the entire content of this Policy.

2. Types of Information Collected

2.1 Information You Actively Provide

   Account Information: Email address, mobile number, username, and password provided when registering for an account.

   Profile Information: Information you choose to include in your profile, such as avatar, nickname, bio, etc.

   User Content: Videos, audio, photos, text (e.g., titles, descriptions, comments) that you upload, publish, or transmit while using the services.

   Contact and Service-Related Information: Email address, text/photo/video messages, User ID, and problem descriptions provided when using customer services.

   Other Interactive Information: Information you provide to us through correspondence such as complaints, support requests, or feedback.

2.2 Information Collected Automatically

   Device Information: Hardware model, operating system version, unique device identifiers (such as Android ID), mobile network information, IP address.

   Usage Information: Includes clicks, tracking, search history, 'liked' or saved content, browsing and transaction history, login history, push notification enablement records, video watch time, etc.

   Advertising-Related Information: Google Advertising ID, and non-precise location information related to your device (e.g., city-level location based on IP address) for optimizing ad delivery and analyzing ad effectiveness. We may collect the list of installed applications on Android devices, primarily for evaluating the performance and relevance of advertising campaigns. You can reset your advertising ID or opt out of personalized ads through the ad settings in your device's operating system.

   Local Storage Information: Storage of personal information on your device through mechanisms such as application data caching.

   Cookies and Similar Technologies: Information such as web browsing history and page interaction behavior collected through Cookies, web beacons, SDKs, and similar technologies, used for experience optimization, advertising delivery, and effectiveness evaluation.

2.3 Information from Other Sources

Third-Party Account Information: Nickname and email address obtained when you log in via your Google account.

Information from Public Sources: Information from public channels such as government publications and publicly available content on social media.

Information Provided by Others: Information related to you mentioned in direct messages, complaints, appeals, or feedback from other users.

3. Purposes of Using Information

1. Providing and Performing Services: Fulfilling our agreement with you, delivering and maintaining services, activating accounts and user profiles.

2. Communication and Response: Notifying you of product announcements, software updates, and responding to your assistance requests.

3. Marketing and Advertising: Sending product information and promotions via inbox messages, displaying targeted ads within the Platform, and evaluating marketing effectiveness.

4. Experience Optimization: Providing personalized content (e.g., video recommendations) based on your preferences, ensuring services are presented in the most effective manner.

5. Security and Safeguarding: Detecting and combating abuse, fraud, and other illegal activities, preventing security risks and technical issues, and protecting the security of your account and the Platform's systems.

6. Complying with Legal Obligations: Responding to judicial proceedings, investigation requests, and complying with relevant laws and Google Play Store regulatory requirements.

7. Technical Development and Research: Training and improving algorithms (e.g., optimizing video recommendation algorithms, enhancing content moderation systems), analyzing usage data to optimize products and services.

4. How Information is Shared

Except as explicitly stated in this Policy, we will not arbitrarily share your personal information. Exceptions include:

4.1 Sharing Based on Your Consent

Sharing your information with third parties based on your explicit consent or instruction.

4.2 Sharing with Business Partners

   Social Networks: When you register using a social network account, sharing necessary information such as nickname, virtual avatar, etc.

   Service Providers: Sharing necessary information with partners providing services such as analytics, IT support, email delivery, customer service, and security detection (partners are required to comply with privacy protection obligations).

   Third-Party SDK Providers: Third-party SDKs integrated into the Platform may collect information directly. Their processing rules follow their own privacy policies. We have conducted prudent reviews of their compliance and security. The specific SDK list, permissions, and related information are provided in subsection 4.3 below.

4.3 Sharing Based on Legal Requirements

   Responding to lawful requests from law enforcement agencies and government regulatory bodies to fulfill legal obligations.

   Enforcing service agreements and platform rules, investigating potential violations, and protecting our legitimate rights.

   Addressing security, fraud, and other issues to protect the rights, property, and safety of us, our users, or the public.

   Cooperating with Google Play Store compliance checks and rule requirements, providing relevant information when necessary (only within the scope permitted by the rules).

5. Third-Party SDK List and Permission Description

To ensure the normal operation of Zapclip's functions and service optimization, the Platform integrates certain third-party SDKs. The following is a detailed list. The information collection and processing by each SDK follow their independent privacy policies, and we have conducted prudent reviews of their compliance and security:

Additional Notes:

1.  The aforementioned SDKs are activated and obtain relevant permissions only when you use the corresponding features (e.g., choosing Google login, playing videos, watching ads). You can disable non-essential permissions through your device system settings or the Platform's permission management features (disabling them may affect the use of corresponding features).

2.  We do not authorize third-party SDKs to collect personal information beyond what is necessary for their functionality. If you find any SDK collecting information in violation of rules, please inform us via the "Section 10 - Contact Us" section of this Policy, and we will promptly investigate and address the issue.

3.  The privacy policies of third-party SDKs may be updated. We recommend that you periodically check their official links for the latest information processing rules.

6. Information Storage and Protection

6.1 Storage Methods

   Storage Location: Your personal information is currently stored on servers (located in Indonesia) compliant with Google Play Store rules. Cross-border transfers will strictly adhere to relevant laws and regulations and Google's data security requirements.

   Retention Period: Information is retained during the existence of your account. After account termination, retention periods are determined based on the type of information, purpose of use, and legal requirements for necessary purposes such as complying with legal obligations and resolving disputes. Upon expiry, information will be deleted or anonymized (anonymized data no longer constitutes personal information).

6.2 Protection Measures

   Technical Measures: Employing technologies such as Transport Layer Security (TLS), classified data storage, multi-factor authentication, and full lifecycle monitoring to prevent unauthorized access and disclosure; adhering to Google Play Store data security specifications to ensure the security of information transmission and storage.

   Administrative Measures: Establishing personal information protection protocols, restricting information access scope; regularly inspecting the security and compliance of third-party partners (including SDK suppliers); promptly responding to data security incidents to mitigate risk impact.

Please note that electronic data transmission and storage cannot guarantee absolute security. We will endeavor to take reasonable measures to ensure security but do not promise permanent information security.

7. Your Rights and How to Exercise Them

In accordance with applicable laws, you have the following rights, which can be exercised through the corresponding methods:

7.1 Core Rights

The right to access your personal information, correct/modify inaccurate information, delete personal information, withdraw consent, opt-out of notifications, choose personalized content, download a copy of your information, and restrict or object to the processing of your information.

7.2 Rights Exercisable Directly Within the Platform

   Access Information: View profile information such as User ID, nickname, etc., via "Profile"; view corresponding content and records via "Works" and "Likes".

   Copy Information: Copy User ID on the profile page.

   Withdraw Authorization: Change granted access permissions (e.g., camera permission) through device settings; permissions for third-party SDKs can be disabled through the device system settings.

7.3 Other Methods of Exercise

If you need to exercise rights not listed above, or encounter difficulties in the exercise process, you can contact us using the methods listed in "Section 10 - Contact Us" of this Policy. After verifying your identity, we will respond within the period stipulated by law (generally not exceeding 30 days, extendable to 45 days in special circumstances). You have the right to appeal our decision or lodge a complaint with the relevant authority according to local law. You may also seek assistance through the Google Play Store customer service channels.

8. Processing of Minors' Information

8.1 Minimum Age Requirement

Zapclip is not directed at children under the age of 13 (or other minimum age specified in certain jurisdictions, such as 16 in the EU), and we do not knowingly collect personal information from individuals under that age.

   Individuals under the minimum age: Please do not use the Platform or provide any personal information. If we discover that we have inadvertently collected such information, we will immediately delete it, terminate the corresponding account, and handle it in accordance with Google Play Store rules.

   Individuals under the age of majority: Must use the Platform with the consent of a parent or legal guardian, who should read this Policy and confirm agreement before you provide personal information.

8.2 Application Child Safety Compliance Statement

This application strictly complies with the Google Play Families Policy and relevant laws and regulations, firmly prohibiting any content, behavior, or functional design that endangers children, and fully safeguarding the physical and mental health and safety of child users. Specific compliance commitments are as follows:

I. Strictly Prohibited Child-Endangering Behaviors and Content

8.2.1 Prohibiting users from creating, uploading, or distributing any content that incites the exploitation or abuse of children, including but not limited to all Child Sexual Abuse Material (CSAM).

8.2.2 Prohibiting the promotion of predatory behavior towards children, including:

   Inappropriate interaction with children (e.g., touching, caressing, or other acts with sexual undertones or physical violation);

   Grooming of children (e.g., befriending children online with the intent of facilitating online or offline sexual contact, exchanging pornographic images, etc.);

   Sexualizing minors (e.g., images depicting, encouraging, or promoting the sexual abuse of children, or content presenting children in a manner that could lead to their sexual exploitation);

   Sexual extortion (e.g., threatening or blackmailing children using their intimate images);

   Trafficking of children (e.g., promoting or luring children for the purpose of commercial sexual exploitation).

8.2.3 Prohibiting any adult themes in features and content directed at children, including:

   Excessively violent or gory content;

   Depictions or encouragement of harmful or dangerous activities;

   Promotion of negative body image or self-image (e.g., depicting plastic surgery, weight loss, and other cosmetic procedures for entertainment purposes).

II. Application Compliance Safeguards

8.3.1 Published Public Standards: Our "Community Guidelines" and "Terms of Service" explicitly prohibit the aforementioned Child Sexual Abuse and Exploitation (CSAE) behaviors. Users must read and agree to these terms before registering and using the app.

8.3.2 In-App Feedback and Reporting Mechanism: A dedicated "Report Violation" entry is available within the app (Path: [Video Details Page → Report Violation]), allowing users to submit concerns, issues, and clues regarding child safety violations, accompanied by evidence such as content screenshots and User IDs.

8.3.3 Child Sexual Abuse Material (CSAM) Handling: Upon becoming aware of CSAM content through user reports, system detection, or third-party notifications, we will immediately initiate a verification process. Upon confirmation of violation, the relevant content will be removed within 12 hours, the violating account will be permanently banned, and relevant evidence will be preserved.

8.3.4 Compliance with Child Safety Laws and Regulations: Establishing specific procedures to report confirmed CSAM to the US National Center for Missing & Exploited Children (NCMEC) or relevant law enforcement agencies in the application's operational region, as required by law.

III. Reporting and Contact Channels

8.4.1 Reporting Child-Endangering Content/Behavior Within the App:

   In-App Reporting: Submit via the "Report Violation" entry mentioned above.

   Email Reporting: Send report information (including content links, screenshots, violating account details, etc.) to [Dedicated Reporting Email: report-csam@zapclip.net].

8.4.2 Discovering Such Content on Other Internet Platforms: Please contact the relevant law enforcement agencies in your country/region directly.

8.4.3 Handling Emergencies: If you believe a child is in immediate danger, being abused, exploited, or trafficked, please contact local law enforcement immediately.

IV. Child Safety Designated Contact

In response to the requirements of the Google Play Families Policy, this application designates the following exclusive contact person responsible for receiving notifications from Google Play and related parties regarding child sexual abuse and exploitation content, explaining the application's violation handling and review procedures, and taking corresponding measures promptly:

   Contact Name: [febby triandanawari]

   Dedicated Safety Email: [child-safety@zapclip.net]

   Contact Phone Number: [+447563709581]

   Response Time: Acknowledgment within 24 hours, processing within 12 hours on business days.

This statement will be dynamically adjusted according to updates to Google Play policies and changes in relevant laws and regulations to ensure ongoing compliance. For any child safety-related questions or suggestions, please communicate via the Child Safety Designated Contact above.

9. International Information Transfer

To provide the services, we may transfer your personal information to third parties (including SDK suppliers, server operators) located outside your jurisdiction. During such transfers, we will:

1.  Follow the cross-border data transfer rules of the Google Play Store.

2.  Review the privacy protection capabilities of the recipients to ensure they meet applicable legal requirements.

3.  Employ lawful transfer mechanisms such as Standard Contractual Clauses or adequacy decisions (e.g., EU GDPR standard clauses) to ensure information security.

10. Contact Us

If you have questions, comments, complaints, or requests regarding this Policy or privacy-related matters, you can contact us through the following methods (Google Individual Developer customer service channels):

   Email Contact: zapclip@hotmail.com (Developer's dedicated customer service email, generally responded to within 5 business days).

   Google Play Store Assistance: Submit requests through the "User Support" channel in the Google Play Console. We will respond in accordance with Google's rules.

We will first verify your identity (e.g., by checking account registration information) and respond to you within the period stipulated by law. You have the right to lodge a complaint with your local data protection authority (e.g., supervisory authority under EU GDPR, California Attorney General) or seek assistance through the Google Play Store dispute resolution channels.

11. Language and Governing Law

   Language Effectiveness: This Policy is written in English. In case of discrepancies between translated versions and the English version, the English version shall prevail (complying with Google Play Store language rule requirements).

   Governing Law: This Policy is formulated, interpreted, and executed in accordance with the applicable laws of your jurisdiction and Google Play Store rules. In case of legal conflict, the mandatory legal provisions of your location shall prevail. Related disputes may be prioritized for resolution through negotiation via the channels in "Section 10 - Contact Us". If negotiation fails, the dispute may be submitted to a court with jurisdiction in your location (or resolved according to Google Play Store dispute resolution rules).

12. Updates to the Privacy Policy

We may update this Policy from time to time due to legal changes, adjustments to Google Play Store rules, updates to business functions, etc. After updating, we will:

1.  Change the "Last Updated" date at the top.

2.  Notify you of significant changes affecting your privacy 7 days in advance via the "Announcements" section in Zapclip, push notifications (if you have them enabled), etc.

3.  If required by law to obtain your consent, seek your consent via pop-up notifications or other methods before the updated policy takes effect (the new policy will not apply before consent is obtained).

We recommend that you check the latest version via "Settings" - "Privacy Policy" each time you use Zapclip. Your continued use of the services constitutes acceptance of the updated Policy.

13. Supplemental Terms - Specific Jurisdictions

If the supplemental terms of a specific jurisdiction conflict with other content in this Policy, the supplemental terms shall prevail.

13.1 Additional Notice for California Residents (Pursuant to CCPA/CPRA)

13.1.1 Information Collection and Disclosure

In the past 12 months, we have collected and disclosed the following categories of personal information:

   Identifiers: Email address, account name, User ID (Sources: Information you provide, third-party accounts).

   Internet or other electronic network activity information: Click/tracking/search/browsing history, interaction information with the Platform (Source: Automatically collected information).

   Audio, electronic, visual, or similar information: Text/photos/videos you provide when contacting customer service (Source: Information you provide).

   Sensitive Personal Information: Account login credentials (used only for security verification, not shared externally) (Sources: Information you provide, third-party accounts).

   Inferences: Preferences, interest analyses derived from the above information (Source: Automated analysis).

We do not knowingly collect information from individuals under 16. If you are a California resident under 16, or their parent/legal guardian, and discover that we have inadvertently collected such information, please inform us immediately via "Section 10 - Contact Us". We will delete the information and confirm within 10 business days.

13.1.2 Information Sale and Sharing

In the past 12 months, we have not sold or shared California residents' personal information as defined by CCPA/CPRA. If such operations are involved in the future, we will notify you in advance through Platform announcements, emails, etc., and provide a clear and easy-to-use "opt-out" mechanism (free of charge). We will not sell or share information without your explicit consent.

13.1.3 Rights of California Residents

   Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information collected about you, the sources, purposes, and third parties with whom it was shared/disclosed over the past 12 months (submit requests via "Section 10 - Contact Us", 2 free reports within 12 months).

   Right to Delete: You have the right to request the deletion of your personal information we have collected (exceptions include information we need to retain for legal obligations, dispute resolution, security, etc.).

   Right to Correct: You have the right to request correction of inaccurate personal information we hold (relevant proof materials required, processed within 5 business days after verification).

   Right to Limit: You have the right to limit the use of sensitive personal information (only for necessary security verification or service provision, not for marketing, analysis, etc.).

   Right to Non-Discrimination: We will not deny you goods/services, charge different prices, or provide a different level or quality of goods/services for exercising your rights.

13.1.4 Methods for Exercising Rights

   Submit a Request: Submit a request via any channel in "Section 10 - Contact Us". Provide your account information (e.g., User ID, registered email) for identity verification. We will complete verification and provide processing progress within 15 business days.

   Authorized Agent: If using an authorized agent, provide a signed power of attorney and identification documents for both parties. We will process according to regulations after verification (no additional fees).

   Feedback and Appeal: If dissatisfied with our handling result, you may appeal within 10 business days of receiving the result. We will re-review and respond within 20 business days. You may also complain to the California Attorney General's office or the California Privacy Protection Agency.

13.2 Additional Notice for European Economic Area (EEA) Residents (Pursuant to GDPR)

13.2.1 Data Controller and Representative

   Data Controller: The independent developer, febby triandanawari. Contact information is provided in "Section 10 - Contact Us".

   EU Representative: To fulfill the requirement of Article 27 GDPR, we have appointed [febby triandanawari] as our representative in the EU. You can contact our EU representative via: [zapclip@hotmail.com, dsn ganggong rt/rw 001/001 desa jantiganggong kecamatan perakkabupaten jombang - 61461 Indonesia (ID)].

13.2.2 Legal Basis for Processing

We process your personal information based on the following legal grounds (compliant with GDPR):

   Your Consent: e.g., collecting advertising identifiers, sending marketing notifications. You can withdraw consent at any time (does not affect the lawfulness of processing based on consent before its withdrawal).

   Performance of a Contract: e.g., processing your account information, usage records to create an account and provide video playback services (necessary and non-substitutable).

   Legitimate Interests: e.g., optimizing service experience, detecting fraudulent behavior, evaluating advertising effectiveness (does not override your fundamental rights and interests, and aligns with public interest or our legitimate business needs).

   Compliance with Legal Obligations: e.g., situations where processing personal information is necessary to respond to judicial authority investigations, fulfill tax declaration requirements, etc.