EraReels Privacy Policy

We are OCEANSALT PTE. LTD. ("OCEANSALT," "we," "us," or "our"), a company incorporated under the laws of Singapore, with its registered office at 192 WATERLOO STREET, #06-08, SKYLINE, SINGAPORE. For purposes of applicable data protection laws, we are the controller of the personal information processed in connection with your use of the EraReels Services. We understand that your privacy is important and are committed to protecting the data and information we collect.

This EraReels Privacy Policy (the "Policy") applies to our application/App EraReels and related products and/or services (collectively, "EraReels," the "Services," or our "Products and/or Services"). This Policy explains our practices for processing and protecting personal information, including what personal information we collect; how we collect, use, disclose, and otherwise process it (collectively, "process" or "processing"); how we safeguard it; the rights available to you; and supplemental terms that apply in certain countries or regions. Please read this Policy carefully before using the Services, particularly the provisions shown in bold.

If you decline to provide personal information that is necessary for us to provide EraReels's core Services, we may be unable to provide the relevant Services to you. For non-core processing activities, such as personalized recommendations, personalized advertising, non-essential analytics, and marketing, we will provide appropriate mechanisms to consent, decline, disable, or withdraw consent as required by applicable law.

This Policy covers the following:

1. How We Collect Your Personal Information

2. How We Use Your Personal Information

3. How We Disclose Your Personal Information to Third Parties

4. Legal Bases for Processing Personal Information

5. International Transfers of Personal Information

6. Information Security

7. Your Privacy Rights and How to Exercise Them

8. Children and Teen Privacy

9. Application of and Updates to This Policy

10. Account Deletion

11. Contact Us

12. Data Protection Officer

Supplemental Terms for Certain Countries and Regions

1. How We Collect Your Personal Information

"Personal information" (also referred to as "personal data") means information relating to an identified or identifiable natural person (a "data subject").

Depending on how and to what extent you use the Services, we may collect the following personal information in the ways described below.

1.1 Information You Provide

When you use the Services, you may voluntarily provide personal information required for particular features or services.

(1) Account Information: When you register an EraReels account, you may need to provide personal information such as your telephone number, account verification information (password or verification code), nickname, profile picture, or email address.

(2) Communications Information: When you communicate with us, including through in-app feedback, instant messaging, or customer-support email, you may provide the contents of those communications, including text, images, and other information. We also automatically collect related metadata, such as the time the communication was sent and received, your approximate location (inferred from your IP address), the customer-service representative who communicated with you, and other descriptive information.

(3) Activity Information: When you participate in our surveys, research, marketing campaigns, or other activities, you may provide information relevant to the activity, such as a delivery address and contact details for a promotional campaign.

(4) Payment Information: If you make a purchase or otherwise incur charges when using our Products and Services, we may collect your payment information (such as your credit card number) and transaction records. If you choose to use any third-party service to complete a payment, you will provide your credit card number and other information directly to that third party and complete the payment through that third party. Please review the third party’s privacy policy before deciding whether to use its services.

1.2 Information We Collect Automatically

When you use the Services, our platform may automatically collect or generate personal information relating to your use of the Services.

(1) Usage Information: We automatically collect information about your interactions with the Services, including your searches, browsing, favorites, sharing, clicks, and viewing activity (such as the time, approximate location inferred from your IP address, and other descriptive attributes); transaction records; app usage information (such as the duration and frequency of use); crash reports and performance data; and other information generated through your interactions with the Services.

(2) Device Information: We automatically collect information relating to your device, including:

Device identifiers: device ID, ICCID, Android ID, IDFV, advertising identifiers (ADID, GAID, PPID, and IDFA), IP address, MAC address, Bluetooth address, and session identifiers;

Device parameters (hardware and software): device model, device name, operating system and version, CPU information, disk and memory capacity, battery status and charge level, screen resolution, and installed app list;

Network information: network operator, network status, and signal strength;

Usage environment: country or region, language, time zone, date, and access time;

Browser information: browser type (user agent), screen resolution, language, and time zone;

Log and performance information: page and launch URLs, referring page, SDK status, network-request results, error logs, and web-performance metrics.

(3) Location Information: We automatically collect information about your approximate location, primarily by inferring it from your IP address.

(4) Inferred Information: We may infer certain information about you, including your age range, gender, channel preferences, and interests.

1.3 Information from Third Parties

(1) Third-Party Account Information: If you sign in to EraReels using a third-party account, we will request access to and share basic information associated with that account, such as your username, profile picture, telephone number, and email address, in order to pre-fill our account registration form. You may stop this sharing at any time by deleting the EraReels account associated with the third-party account. When you are not signed in to our Products, we may obtain necessary information from the app and device you use, such as language preferences and geographic location.

(2) Analytics and Statistical Information: We may receive and process personal information about you from other sources, including publicly available sources. For example, we may receive personal information from commercial sources, such as public databases where permitted by law, and from third-party services, such as social-media companies, advertising partners, and analytics providers.

(3) Other Information: We may obtain information about you through other channels, including where you are mentioned or included in a complaint, appeal, request, or feedback submitted to us, or where you provide us with your contact details. We may also collect information about you from other public sources, whether before or after you register an account.

If you use EraReels as a guest, we do not collect account-registration information such as your email address. We may nevertheless process device and network information, service logs, and information relating to your use of the Services as described in this Policy.

2. How We Use Your Personal Information

2.1 Purposes for Which We Use Personal Information

We use your personal information only as permitted by applicable law, generally for the purposes described below. If you do not provide personal information required for a particular feature or service, you may be unable to use that feature or service, but this will not affect your use of other features or services. We may also use your information to personalize the content you see on the platform, promote the platform, and personalize your advertising experience on and off the platform, where applicable.

(1) Providing the Services: To make the EraReels Services and content available to you, including video streaming, resume-playback, favorites, sharing, and other information, products, or services that you authorize us to provide; to support interactive platform features, including allowing you to comment on, like, favorite, and share videos and to interact publicly with other users; and to generate and maintain your viewing history and preference settings.

(2) Improving the Services: To improve and personalize the Services by providing new content, services, information, recommendations, and feedback.

(3) User Administration: To administer registered-user accounts, provide registered users with support and notices relating to their accounts or subscriptions, and notify them of changes to the EraReels Services or any other products or services we make available through them.

(4) Communications: To communicate and interact with you directly. For example, we may send you notices about upcoming changes to the EraReels Services, new series releases, promotions, or improvements.

(5) Content Moderation: To review images, visual materials, and content posted or generated through the EraReels Services, including user comments, profile pictures, nicknames, reviews, bullet comments, and promotional materials, in order to comply with applicable content laws in relevant jurisdictions.

(6) Personalized Recommendations: To research and analyze your interests in the content, products, advertisements, or services available through EraReels so that we can develop, display, or recommend content that is more relevant to your interests. In particular, this feature uses the information identified in Section 1 of this Policy (excluding your private messages and non-public group chats) to create a user profile and provide personalized recommendations. Please note that an individual item of information may not, by itself, identify a particular natural person. If we combine that information with other information in a way that identifies a particular natural person, we will anonymize or de-identify it during the combined use, unless we have obtained your authorization or applicable law provides otherwise. If you do not want us to use your information for this purpose, you may disable personalized recommendations by following the instructions in the system settings or by emailing oceansaltvip@gmail.com. You may continue to use the platform after disabling this feature, but the content and advertisements you receive may be less personalized.

(7) Performance Analytics: To determine whether users of the EraReels Services are unique or whether the same user accesses the Services multiple times; monitor aggregate metrics such as active-user numbers, video views, and average viewing time; and optimize service stability, content supply, and operational strategy.

(8) Functionality and Security: To verify users' identities for security purposes; identify users who do not meet applicable age requirements; diagnose or resolve technical issues; detect, prevent, and respond to actual or suspected fraud, inappropriate spending by minors, minors' access to unsuitable content, unlawful activity, or intellectual-property infringement; and help us detect and combat abuse, harmful activity, fraud, spam, and unlawful activity on the platform.

(9) Compliance: To enforce our Terms of Service and comply with our legal obligations, including regulatory inquiries, audits, disclosure requirements, and obligations relating to the protection of minors.

(10) Aggregation: To aggregate information we collect about you for one or more of the purposes described above.

If we wish to use your personal information for another purpose not disclosed in this Policy, we will inform you of the new purpose by updating this Policy or through another appropriate means, and will obtain your consent or rely on another valid legal basis, as applicable.

2.2 How Long We Retain Personal Information

Retention periods vary depending on the type of information and the purpose for which it is processed. To the extent permitted by applicable law, we generally retain personal information only for as long as necessary to provide the Services and fulfill the purposes described in this Policy. More specifically:

(1) We generally retain your account information and profile for as long as your account remains active. After you delete your account, we will delete or anonymize the relevant information unless applicable law requires otherwise or we need to retain it for one of the legitimate reasons described below.

(2) We retain your browsing activity, playback activity and progress, favorites, and other service-usage information for as long as necessary to provide the relevant features, synchronize service status, and maintain the proper operation of the Services. When this information is no longer necessary for those purposes, or when you delete your account or submit a valid deletion request, we will delete or anonymize it unless applicable law requires otherwise.

(3) We retain device, network, and technical log information for as long as necessary to troubleshoot issues, safeguard the Services, prevent fraud or abuse, and maintain system stability. The specific period depends on the type of log, whether the relevant issue or security incident has been resolved, and the applicable system-rotation cycle.

(4) We retain customer-service records, complaints, and other communications until the relevant matter has been resolved, and may retain them for an additional period as necessary for follow-up, dispute resolution, or compliance with legal obligations.

If you violate our agreements, terms, or applicable rules, we may retain relevant information for as long as necessary to investigate and address the conduct, process appeals, prevent repeat violations, and protect the security of the Services.

We may also retain personal information for as long as necessary to perform a contract or comply with legal obligations, respond to requests from regulators or judicial authorities, or establish, exercise, or defend legal claims. Relevant information may remain in backup systems for a limited period until it is overwritten or deleted through our ordinary backup-rotation cycle. During that period, we will segregate and protect it and restrict further processing.

When the applicable retention period expires, or when we no longer have a lawful, reasonable, and clearly defined purpose for processing, we will delete or anonymize your personal information. If legal requirements or technical limitations temporarily prevent us from doing so, we will securely store and restrict the processing of the information and delete or anonymize it promptly once the restriction no longer applies.

3. How We Disclose Your Personal Information to Third Parties

In the circumstances described below, we may share, transfer, entrust others to process, or otherwise disclose your personal information to the extent necessary. We do not sell your personal information.

3.1 OCEANSALT Group Affiliates

The Services may be provided or supported by OCEANSALT group affiliates as part of our commercial operations. They may process information you provide, information we collect automatically, and information from third parties in order to provide necessary functions, such as research and development, storage, security, content delivery, analytics and statistics, customer and technical support, and service optimization and improvement.

3.2 Third-Party Partners

We may share your personal information with the following categories of third-party partners to the extent necessary to provide the relevant Services.

(1) Third-Party Platform Partners

Certain services offered by third-party platform partners may be integrated into our platform, such as account registration or sign-in, content sharing, and third-party payments. When you use both the Services and an integrated service provided by a third-party platform partner, we may share automatically collected information, such as device information, with that partner to ensure the relevant feature functions properly and smoothly.

(2) Content Partners

Content on EraReels may be provided by us or by third-party content partners. To the extent necessary, we may share de-identified or aggregated information relating to content playback, viewing statistics, and payment settlement with those partners to administer content collaborations, revenue sharing, and settlement. Except as necessary for those purposes, we do not provide them with information that identifies you personally.

(3) Campaign Partners

We may conduct joint marketing campaigns with third parties and share campaign information, such as contact details, with campaign partners so they can deliver prizes or gifts to you in a timely manner.

(4) Advertising Partners (Including Advertisers, Advertising Service Providers, Advertising Measurement Companies, and Other Partners)

Advertising services are an important source of revenue that supports the operation of our platform. Advertising partners may collect certain personal information from you through the platform, or we may share automatically collected information with them, such as device, location, and inferred information, to improve ad delivery, recommend personalized advertisements, facilitate your interaction with advertisements, and measure and improve advertising effectiveness. These advertising partners do not collect your profile information from our platform.

(5) Marketing Partners

To conduct marketing and promotional activities and to measure and optimize campaign performance, we may work with agencies, marketing-platform service providers, and providers of campaign measurement and optimization services (collectively, “Marketing Partners”). Marketing Partners may collect automatically collected information through our Services, or we may share such information with them, including device information, location information, network information, IP address, advertising identifiers or other device identifiers, marketing-source information, deep-link information, and in-app event information and related timestamps, such as app installs, first launches, registrations, playback, subscriptions, top-ups, and purchases.

We use this information to identify whether you installed or used EraReels through a particular marketing campaign; to measure, attribute, and optimize the performance of marketing campaigns; to prevent marketing fraud; and to generate statistical and analytical reports. Depending on the applicable configuration, we may transmit necessary attribution or conversion information to advertising platforms such as TikTok, Meta, and Google, or their affiliated partners.

For these purposes, EraReels may currently use the following SDKs for mobile attribution and performance measurement:

Adjust SDK

Privacy Policy: https://www.adjust.com/terms/privacy-policy

AppsFlyer SDK

Privacy Policy: https://support.appsflyer.com/hc/en-us/sections/6551440878097-Preserve-user-privacy

Singular SDK

Privacy Policy: https://www.singular.net/privacy-policy/

We manage the collection, use, and sharing of the above information in accordance with applicable laws, our arrangements with Marketing Partners, and your privacy choices. Where required by applicable law, we will obtain your consent before processing information for marketing attribution or advertising-performance measurement purposes, or provide you with applicable choice and opt-out mechanisms.

3.3 Service Providers

We engage service providers to provide or support the Services on our behalf and to assist with the development, operation, and improvement of our Products and/or Services. Their services include IT and infrastructure, customer service, marketing, research, analytics and statistics, security and risk management, and service optimization and improvement. Service providers act only as processors and process personal information on our instructions to the extent necessary to provide their services.

3.4 Corporate Transactions

If we are involved in a merger, acquisition, reorganization, demerger, bankruptcy, asset transfer, or similar transaction, your personal information may be transferred as part of that transaction. We will notify you as required by applicable law and use reasonable efforts to require the new controller to continue to comply with this Policy.

3.5 Disclosures to Public Authorities

In certain circumstances, we may disclose your personal information to public authorities, including administrative, judicial, and other regulatory authorities and third parties designated by them, as required by applicable law or by those authorities. We may do so to comply with legal obligations and procedures and to protect the lawful rights and interests of you, us, our users, the public, or other third parties. Subject to applicable law and valid legal process, including subpoenas, court orders, and search warrants, these disclosures may be made with or without your consent and with or without notice to you, and we may be prohibited from notifying you of the disclosure.

3.6 Information Made Public on the Platform

We seek to enhance users' ability to interact with one another through the Services. Your personal information and content that you make public, including comments, profile pictures, nicknames, and other information you choose to disclose, will be displayed publicly on the platform and may be viewed by other users. Third parties such as search engines and content aggregators may also access, collect, or share that content. Please consider carefully before posting publicly and avoid disclosing personal information about yourself or others.

4. Legal Bases for Processing Personal Information

In some countries or regions, applicable data protection law requires us to satisfy a legal condition (a "legal basis") when we collect, use, disclose, or otherwise process your personal information. The legal bases recognized in different countries and regions vary, but commonly include the following:

(1) Your consent as the data subject: Where none of the legal bases below applies, we will ask for your consent.

(2) Necessity for entering into or performing a contract with you: For example, we need to process certain personal information to provide the Services under the EraReels Terms of Service.

(3) Necessity for compliance with our legal obligations: For example, we may need to process personal information to comply with applicable law or requirements imposed by administrative or judicial authorities.

(4) Necessity for our or a third party's legitimate interests: For example, we may need to process personal information to pursue legitimate interests such as maintaining the security and reliability of the Services and conducting marketing activities.

5. International Transfers of Personal Information

We store your personal information on servers located in the United States. The laws of countries or regions where your information is processed may differ from those of your country or region. We take appropriate steps to help ensure that information is transferred securely and used lawfully. If you do not want your information to be transferred outside your country or region for processing or storage, please do not use our websites, applications, and/or Services.

In addition, our affiliates in other countries, including China, and our third-party partners may be granted remote access to certain personal information, or we may transfer certain personal information to countries or regions where our affiliates' and third-party partners' data centers are located.

Some or all of these entities may be located outside your country or region, where applicable data protection laws may differ from those in your country or region. We nevertheless require such transfers to comply with applicable data protection laws and this Policy. We also use organizational, technical, and contractual measures designed to safeguard these transfers and ensure that personal information receives an adequate level of protection after transfer. For transfers within our corporate group, we enter into intra-group data-transfer agreements requiring our affiliates to protect your personal information when processing it to provide the Services.

6. Information Security

We use appropriate technical and organizational measures to protect the personal information we collect and process. These measures are designed to provide a level of security appropriate to the risks associated with processing your personal information. For example, we use commonly accepted network protocols to encrypt and protect data; maintain access controls designed to ensure that only authorized personnel can access users' personal information; and provide security and privacy training from time to time to reinforce our employees' understanding of the importance of protecting personal information.

To help prevent security incidents, we maintain a dedicated data-security function and have established warning mechanisms and incident-response plans. If a personal-information security incident occurs, we will notify you promptly in an appropriate and sufficiently detailed manner as required by applicable law and will activate our incident-response plan without delay to mitigate harm.

However, transmission of information over the Internet is not completely secure. Although we use measures such as encryption to protect your personal information, we cannot guarantee the security of information transmitted through the platform, and any transmission is at your own risk.

7. Your Privacy Rights and How to Exercise Them

7.1 Your Privacy Rights

You have the rights provided by applicable law in relation to your personal information. These rights commonly include those described below, although the rights and conditions that apply to you may vary by country or region.

(1) Right to Be Informed

You have the right to be informed about how we process your personal information.

We have prepared and published this Policy to explain how we process and protect your personal information. You may also contact us to request further information or clarification.

(2) Right of Access

You have the right to ask whether we process your personal information and to access, review, and obtain a copy of personal information we hold about you.

You may access and review certain personal information at any time by signing in to your EraReels account. You may also contact us to request access to or a copy of additional personal information, which we will provide electronically.

(3) Right to Rectification

You have the right to ask us to correct, complete, or update personal information about you that is inaccurate, incomplete, or out of date.

You may correct certain personal information, such as your country or region of residence, at any time by signing in to your EraReels account. You may also contact us to request that we correct, complete, or update other personal information.

(4) Right to Data Portability

In certain circumstances provided by applicable law, such as where processing is based on your consent or is necessary to enter into or perform a contract with you, you may ask us to provide your personal information in a structured, commonly used, machine-readable format or to transmit it to another controller you designate.

You may contact us to exercise your right to data portability.

(5) Right to Deletion

In certain circumstances provided by applicable law, you may ask us to delete your personal information, including where the purpose of processing has been fulfilled, you withdraw consent and no other legal basis applies, or the processing is unlawful. We may nevertheless retain the information where applicable law requires or permits us to do so for legitimate reasons.

You may delete certain personal information at any time by signing in to your EraReels account. You may also contact us to request deletion of other personal information. Please note that deleting personal information may affect our ability to provide the relevant features or Services.

We will delete or anonymize your personal information promptly as required by applicable law. If legal requirements or technical limitations prevent immediate deletion, we will store the information securely, stop processing it for other purposes, and delete it promptly when the limitation no longer applies.

(6) Right to Restrict Processing

In certain circumstances provided by applicable law, you may restrict our processing of some or all of your personal information, including while the accuracy of the information is disputed.

You may contact us to request that we suspend processing of your personal information.

(7) Right to Object

In certain circumstances provided by applicable law, you may object to our processing of your personal information, including where the processing is based on legitimate interests or the public interest.

You may contact us to request that we stop processing your personal information for a particular purpose.

You have the right to opt out of receiving marketing communications and personalized recommendations from us.

(8) Consent and Withdrawal of Consent

Where processing is based on your consent, you may decide whether to consent to our processing of your personal information as described in this Policy and may withdraw your consent at any time.

You may withdraw consent for certain processing activities at any time by signing in to your EraReels account and using available controls, such as permission settings. You may also contact us to withdraw consent.

After you withdraw consent, we will stop the relevant processing and may therefore be unable to continue providing the corresponding Service. Withdrawal does not affect the lawfulness of processing carried out on the basis of your consent before withdrawal.

(9) Right Not to Be Subject to Automated Decision-Making

You have the right not to be subject to a decision based solely on automated processing, including profiling, where that decision produces legal effects concerning you or similarly significantly affects you.

If we engage in additional forms of automated decision-making, including profiling, in the future, you may contact us to exercise this right.

(10) Unsubscribe

You may opt out of receiving marketing communications from us at any time, where applicable.

For marketing emails or text messages we send you, you may unsubscribe by selecting the "unsubscribe" link or following the other instructions included in the communication. To opt out of other forms of marketing, contact us at oceansaltvip@gmail.com.

(11) Disable Notifications

We may send you information about our Products and/or Services through push notifications, in-app messages, or similar channels. If you do not wish to receive these notifications, you can disable them in your device settings.

(12) Complaints and Legal Proceedings

If you believe that our processing of your personal information violates applicable law, you may lodge a complaint with a data protection authority or bring proceedings before a court.

7.2 Exercising Your Rights and Our Response

You will not be discriminated against for exercising your privacy rights.

To exercise your rights or ask a question about them, contact us at oceansaltvip@gmail.com. You may also be able to exercise certain rights more conveniently through the online features described above.

We will respond to your request promptly and within a reasonable period as required by applicable law. To protect your information, we may need to verify your identity before responding. We generally do not charge a fee for reasonable requests. We may, however, charge a reasonable fee or decline to act on requests that are excessive, repetitive, or manifestly unfounded, where permitted by law.

Please note that privacy rights are not absolute. Applicable law may make a right subject to conditions or limitations, including for national security, public safety and the public interest, the prevention and investigation of crime, or the protection of others' lawful rights and interests. If we cannot fulfill all or part of your request, we will explain why. We will also explain if a particular right is unavailable under the law that applies where you live or is subject to additional conditions or limitations.

8. Children and Teen Privacy

8.1 EraReels is not intended for children under 13. If you are under 13, or below a higher minimum age required by the law of your jurisdiction, do not register for or use EraReels. If you are at least 13 and meet the applicable minimum-age requirement, but are under 18 (or the age of legal majority where you live), please review this Policy with a parent or legal guardian and use EraReels only with their express consent and under their guidance.

8.2 We take the protection of minors' personal information seriously. Minors should exercise care when providing personal information and do so under the guidance of a parent or guardian. A parent or guardian may contact us at any time to request access to, correction of, or deletion of personal information relating to a minor in their care, or to ask us to stop collecting it.

8.3 We protect the confidentiality and security of minors' personal information in accordance with applicable law and this Policy. If we learn that we have collected personal information from a child under 13, or below the applicable minimum age, we will stop providing the Services to that child and delete the relevant personal information as soon as reasonably practicable or take other appropriate compliance measures.

8.4 EraReels maintains strict rules for processing minors' information. We apply data-minimization principles to minor users, limit the collection of unnecessary sensitive information, and provide appropriate safeguards for younger users based on platform functionality. If you are a parent or guardian and have questions about this processing, please contact us promptly.

9. Application of and Updates to This Policy

We may update and publish this Policy from time to time to reflect changes in applicable law or the development of the Services. We will provide notice as required by applicable data protection law, which may include one or more of an announcement, push notification, pop-up notice, or email.

If you continue to use the Services after an updated version of this Policy takes effect, you will be deemed to have accepted the update to the extent permitted by applicable law. If you do not accept the updated Policy, you may stop using the Services, including by deleting your EraReels account.

For the date on which this Policy was last updated, please see the "Effective Date" at the beginning of this Policy.

You can always view the latest version of this Policy at: Profile > Settings > Privacy Policy.

10. Account Deletion

We provide a mechanism for deleting your EraReels account. You may request account deletion by emailing oceansaltvip@gmail.com, unless applicable law or this Policy provides otherwise.

Please note that once your account has been deleted:

(1) You will no longer be able to use your EraReels account;

(2) You will forfeit any unused benefits arising from your use of the EraReels Services and any anticipated future benefits, and you will not be entitled to ask us to recover any content, information, data, or records associated with your account, except as otherwise required by applicable law or a regulatory authority; and

(3) Your account cannot be restored after deletion is complete.

Unless this Policy provides otherwise, your account must also meet all of the following conditions before it can be deleted:

(1) The account belongs to you and was registered through an EraReels Product;

(2) The account has no unresolved transactions or outstanding benefits or assets, if any;

(3) The account is not subject to any unresolved dispute, including a complaint, report, litigation, arbitration, or regulatory investigation; and

(4) Any other conditions reasonably necessary to protect the security of your account and your property interests are satisfied.

You acknowledge and agree that deleting your account does not release you from any liability arising from your use of that account.

11. Contact Us

If you encounter an issue relating to personal information or privacy when using the Services, or if you have a question, complaint, or suggestion about this Policy, you may contact us as follows:

In-App Feedback: Profile > Feedback

Email: oceansaltvip@gmail.com

12. Data Protection Officer

Name: Wang Han

Email: oceansaltvip@gmail.com

Address: 192 WATERLOO STREET, #06-08, SKYLINE, SINGAPORE.

Where required by applicable data protection law, we may appoint a representative in a particular country or region. Please see the Supplemental Terms for Certain Countries and Regions below.

Supplemental Terms for Certain Countries and Regions

Singapore

1. International Transfers of Personal Information

We transfer personal information internationally as described in Section 5 of this Policy, including to countries or regions outside Singapore.

European Economic Area, United Kingdom and Switzerland

1. Legal Bases for Collecting and Processing Personal Information

For each processing purpose described in Section 2.1 of this Policy, we rely on the following legal bases:

2. International Transfers of Personal Information

When we transfer your personal information to a country or region outside the European Economic Area, the United Kingdom, or Switzerland, we use the following transfer mechanisms to help ensure that your personal information is adequately protected:

(1) Adequacy Decisions. Under Article 45 of the European Union General Data Protection Regulation ("GDPR"), personal information may be transferred to a third country or international organization where the European Commission has determined that the third country, a territory or one or more specified sectors within it, or the international organization provides an adequate level of protection. Such transfers do not require specific authorization. We may rely on an adequacy decision to transfer certain personal information described in this Policy to third parties located in countries or regions recognized as providing adequate protection.

(2) Standard Contractual Clauses. Under Article 46 of the GDPR, the Standard Contractual Clauses approved by the European Commission are an appropriate safeguard and are also recognized for transfers under UK and Swiss law. Where the destination is not covered by an adequacy decision, we enter into Standard Contractual Clauses with the recipient, including EraReels group affiliates, and use the UK Addendum where applicable, to govern the transfer of your personal information.

United States

1. Collection and Use of Personal Information

(1) The categories of personal information we have collected in the preceding 12 months are described in Section 1 of this Policy.

(2) The categories of personal information actually collected and used depend on how and to what extent you use the Services. Please see Section 2.1 of this Policy. You may also contact us using the details in Section 11 for more information.

(3) In certain states, including California, the following information may constitute sensitive personal information: your EraReels account credentials and account-verification information, such as a password or verification code. Please see Sections 2.1 and 3 of this Policy for the purposes for which we use sensitive personal information and the circumstances in which we disclose it to third parties.

(4) In certain states, including Virginia, consent is required to process sensitive personal information. We do not collect or process personal information that constitutes sensitive data under Virginia's applicable data protection law.

(5) EraReels is not directed to children under 13. We process the personal information of users aged 13 to 17 in accordance with Section 8 of this Policy and applicable law.

2. Disclosure of Personal Information (Including Sharing)

(1) The categories of personal information we have disclosed to third parties in the preceding 12 months are described in Section 3, read together with Section 1, of this Policy. The categories actually disclosed depend on how and to what extent you use the Services. You may also contact us using the details in Section 11 for more information.

3. Your Privacy Rights

In addition to the rights described in Section 7 of this Policy, you may have the following rights, subject to the data protection law of your state:

(1) Right to Limit the Use and Disclosure of Sensitive Personal Information: You may limit our use and disclosure of sensitive personal information to what is necessary to provide the Services to you.

(2) Right to Opt Out: You may ask us to stop the following activities, and we will do so unless you authorize us to continue:

Cross-context behavioral advertising or other personalized targeted advertising;

Profiling in furtherance of decisions concerning your access to or use of the Services based on your past activities;

Selling or otherwise transferring your personal information to third parties.

(3) Identity Verification, Authorized Agents, and Appeals: Only you or an agent you have lawfully authorized may submit a request concerning your personal information. In your request, or if we ask for additional information, you or your authorized agent must provide enough information for us reasonably to verify that you are the person whose personal information was collected. The amount of information required will depend on your prior interactions with us and the sensitivity of the personal information requested. We may ask you to provide information to verify your identity. If the information you provide is insufficient for us reasonably to verify your identity, we will be unable to fulfill your request. We will use verification information only to verify your identity and fulfill your request. We may deny the request if we cannot verify your identity. If your request is denied, you may appeal our decision by contacting us at the email address above and describing the decision you wish to appeal.

Canada

If you access or use EraReels in Canada, this section applies to you. If this section conflicts with any other part of this Policy, this section prevails. Depending on your province of residence, our business activities, and the nature of the processing, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws may apply together or separately. Quebec residents are also protected by Quebec's Act respecting the protection of personal information in the private sector and other applicable laws.

1. Scope and French-Language Services

When providing Services to Quebec residents, we will make available, as required by law, a French version of this Policy and of material privacy notices, consent interfaces, privacy settings, customer support, and channels for exercising personal-information rights relating to the EraReels Services. French-language services will be comparable to services in other languages in accessibility, response times, and service quality.

If the Terms of Service, subscription terms, or related documents constitute a contract of adhesion or related document under applicable law, we will provide the French version first or at the same time, where required. After receiving the French version, you may expressly choose to enter into the contract in another language as permitted by law. Websites, in-app commercial information, and other content directed to Quebec users that must be provided in French by law will also be available in a complete French version of comparable quality.

2. Minors

EraReels is not directed to users who reside in Quebec and are under 14 years of age, or to users who reside elsewhere in Canada and are under 13 years of age. Users below the applicable minimum age may not register for or use EraReels. We may use age-assurance measures proportionate to the relevant risk.

If we learn that a user is below the applicable minimum age, we will stop providing the Services to that user and delete the relevant personal information or take other appropriate measures as required by law. For users who meet the minimum age but have not reached the applicable age of majority, we will provide privacy information in a manner appropriate to their age and understanding and obtain consent from a parent or legal guardian where required by applicable law.

3. Consent and Privacy Choices

Where consent is required, we will explain the purposes and reasonably foreseeable consequences of the processing and obtain valid consent before collecting, using, or disclosing personal information. We will obtain express consent as required by applicable law for sensitive personal information, processing outside reasonable expectations, or processing that may create a significant residual risk.

For Quebec residents, requests for consent will be made clearly, freely, on an informed basis, and for specific purposes, using plain language for each purpose. Written requests for consent will be presented separately from other information. We will obtain express consent where required by law to use or disclose sensitive personal information. You may withdraw consent on which processing is based, but withdrawal does not affect the lawfulness of processing before withdrawal and may prevent us from providing a particular feature that depends on that information.

You may turn off personalized recommendations, opt out of marketing communications, or adjust other available privacy choices as described in Section 7 of this Policy. If processing is not necessary to provide a core Service, refusing or withdrawing consent will not affect your continued use of core features unrelated to that processing.

4. Transparency, Profiling, and Automated Decisions

When we use technology that can identify, locate, or analyze your preferences, interests, or behaviour, we will, to the extent required by applicable law, inform you in advance how the technology is used and how to activate or deactivate the relevant function. For technology-based products or services offered to the public with privacy settings, we will configure those settings by default to the highest level of confidentiality as required by Quebec law, subject to statutory exceptions.

If we make a decision about you based exclusively on automated processing of your personal information, we will inform you of the use of automated processing no later than when we notify you of the decision. At your request and to the extent required by applicable law, we will explain the personal information used to make the decision, the reasons for the decision, and the principal factors and parameters that led to it, and will inform you of your right to correct the relevant personal information. You may submit observations to a member of our staff who is qualified to review the decision.

Where applicable, personal information used to make a decision concerning a Quebec resident will be retained for at least one year after the decision is made, as required by law. We will conduct a privacy impact assessment for information-system or electronic-service projects involving personal information where required by applicable law and will consult the person in charge of the protection of personal information from the outset of the project.

5. Your Privacy Rights in Canada

In addition to the rights described in Section 7 of this Policy, you may, as provided by law, ask us to confirm whether we hold personal information about you; access that information and learn how it has been used and disclosed; and correct, complete, or update information that is inaccurate, incomplete, or ambiguous. You may also withdraw consent to the use or disclosure of personal information and, where permitted by applicable law, request deletion or cessation of particular processing.

Subject to the conditions prescribed by law, Quebec residents may also request personal information that they provided to us and that we hold electronically in a structured and commonly used technological format, or ask us to transmit it to a person or body authorized by law to receive it. This right does not apply to information created or inferred by us through analysis and may be subject to statutory limitations, including serious practical difficulties.

Subject to the conditions prescribed by Quebec law, you may also ask us to cease disseminating personal information about you or to de-index or re-index a hyperlink associated with your name that provides access to that information by technological means. We will assess such requests by considering whether the dissemination is lawful, the harm to your privacy or reputation, the public interest in access to information and freedom of expression, whether the information concerns a minor, and other factors prescribed by law.

You or a duly authorized representative may submit a request using the methods listed in Section 11 of this Policy. To prevent unauthorized access, we may ask you to verify your identity or the representative's authority. We will process written access or correction requests governed by applicable Canadian or Quebec law as soon as possible and generally provide a written response no later than 30 days after receipt. If the law permits an extension or refusal, we will notify you as required of the reasons, the extended period, and the available complaint or recourse procedures.

6. Security, Retention, and Privacy Incidents

We use reasonable administrative, technical, and physical safeguards appropriate to the sensitivity, quantity, purposes, distribution, and storage media of personal information. We limit access by employees and service providers to what is necessary for their duties and use internal policies, access controls, contractual obligations, and other measures to reduce the risk of unauthorized access, use, disclosure, loss, or other compromise.

We establish and implement rules governing personal-information governance, complaint handling, retention, and destruction. When the purposes of processing have been fulfilled and the law no longer requires retention, we will delete the personal information or, where permitted by law and for serious and legitimate purposes, anonymize it.

If a security or confidentiality incident involves the personal information of users in Canada, we will assess the sensitivity of the information, the reasonably foreseeable consequences, and the likelihood of misuse. If the incident meets an applicable notification threshold, we will report it as soon as possible to the Office of the Privacy Commissioner of Canada, the Commission d'accès à l'information du Québec, or another applicable regulator, and notify affected individuals. We will keep incident records as required by applicable law and take reasonable steps to reduce harm and prevent similar incidents.

7. International Transfers of Personal Information

As described in Section 5 of this Policy, we transfer your personal information outside Canada, including to the United States and China, for storage or processing. Regardless of where the information is processed, we remain responsible as required by applicable law for personal information processed on our behalf and use contractual requirements, security measures, and other appropriate means to require recipients to provide protection comparable to that required by applicable Canadian privacy law.

Before transferring the personal information of Quebec residents outside Quebec, or engaging a service provider outside Quebec to collect, use, disclose, or retain that information, we will conduct a privacy impact assessment where required by applicable law. The assessment will consider the sensitivity of the information, the purposes of its use, contractual and technical safeguards, and the legal framework of the destination. We will proceed only if the assessment indicates that the information will receive adequate protection, and we will address the assessment results and necessary risk-mitigation measures in a written agreement.

While your personal information is stored or processed outside Canada or Quebec, it may be subject to local laws and may be lawfully accessed by courts, law-enforcement agencies, regulators, or national-security authorities under those laws. You may contact us using the methods listed in Section 11 of this Policy to obtain information about cross-border processing that applicable law permits us to disclose.

8. Requests, Contact, and Complaints

Our person in charge of the protection of personal information oversees requests and complaints concerning the personal information of users in Canada. You may submit a request or complaint to oceansaltvip@gmail.com using the contact information in Sections 11 and 12 of this Policy. Quebec residents may submit requests in French and receive responses in French.

If you are dissatisfied with our response, you may lodge a complaint with the applicable regulator, including the Office of the Privacy Commissioner of Canada: www.priv.gc.ca; the Commission d'accès à l'information du Québec: www.cai.gouv.qc.ca; or another applicable privacy regulator in your province or territory.

Australia

1. International Transfers of Personal Information

As described in Section 5 of this Policy, we transfer personal information outside Australia, including to the United States and China, for storage or processing. Where required by applicable law, before disclosing personal information to an overseas recipient, we take reasonable steps to require the recipient to handle the information in accordance with the Australian Privacy Principles or comparable privacy and security standards, subject to any exceptions under applicable law.

2. Your Privacy Rights

In addition to the rights described in Section 7 of this Policy, you may request access to personal information we hold about you or ask us to correct information that is inaccurate, incomplete, out of date, or misleading. We will process your request within a reasonable period. If we lawfully refuse all or part of your request, we will explain the reason and any further steps available to you to the extent required by applicable law.

If you believe that we have breached applicable Australian privacy law or the Australian Privacy Principles, you may submit a written complaint using the contact details in Section 11 of this Policy and describe the relevant facts and the outcome you seek. We will investigate and respond within a reasonable period. If you are dissatisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner ("OAIC"). For information about making a complaint, visit www.oaic.gov.au.

New Zealand

1. International Transfers of Personal Information

As described in Section 5 of this Policy, we transfer personal information outside New Zealand, including to the United States and China, for storage or processing.

Where permitted by applicable law, we disclose personal information to a recipient outside New Zealand only where one or more of the following conditions applies:

(1) The recipient is subject to New Zealand's Privacy Act 2020 or privacy laws that provide comparable safeguards;

(2) The recipient is required by contract, binding rules, or another mechanism to provide comparable safeguards;

(3) After we expressly inform you that the overseas recipient may not provide protections comparable to those under New Zealand law, you expressly authorize the disclosure; or

(4) Another circumstance permitted by applicable law applies.

2. Your Privacy Rights

In addition to the rights described in Section 7 of this Policy, you have the following rights:

You may request access to personal information we hold about you or ask us to correct information that is inaccurate, incomplete, out of date, or misleading.

We will process your access or correction request as soon as reasonably practicable and generally decide whether to grant it no later than 20 working days after receiving it. If applicable law permits us to extend that period, we will notify you of the extended deadline and the reason for the extension. If we do not agree to make a requested correction, you may ask us to attach a statement of correction to the relevant record.

If you believe that we have breached applicable New Zealand privacy law, you may contact us using the details in Section 11 of this Policy. If you are dissatisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner. For information about making a complaint, visit www.privacy.org.nz.