Privacy

This Global Master Terms of Service, Privacy Policy & Data Governance Agreement ("Agreement") is drafted as a comprehensive, unified, and exhaustive legal instrument governing all aspects of access to and use of the Soplè platform. This document is intentionally extensive, detailed, and explanatory in nature to ensure maximum clarity, transparency, and legal protection for Soplè.

This Agreement is entered into between PT. Soplè Media Indonesia, a company duly incorporated under the laws of the Republic of Indonesia ("Soplè", "we", "us", or "our"), and any individual or legal entity who accesses, installs, downloads, registers for, browses, views, uploads content to, interacts with, or otherwise uses the Soplè application, website, software, algorithms, servers, or related services (collectively, the "Services").

By clicking the "Agree", "Accept", "Continue", or similar button, or by otherwise accessing or using the Services, the User expressly acknowledges that:

(i) the User has read this Agreement in its entirety;

(ii) the User fully understands the legal consequences of agreeing to this Agreement;

(iii) the User voluntarily and knowingly agrees to be legally bound by all terms contained herein;

(iv) the User irrevocably waives and releases Soplè from liability to the maximum extent permitted by law; and

(v) the User agrees that Soplè shall not be blamed, sued, or held liable for any matter arising from the User's use of the Services.

If the User does not agree to any part of this Agreement, the User must immediately cease all use of the Services.

1. Definitions, Interpretation & Scope

This Agreement applies globally and without territorial limitation. The headings used herein are for convenience only and shall not affect interpretation.

For the purposes of this Agreement, unless the context otherwise requires:

A "User" refers to any individual or legal entity who accesses or uses the Services, whether such use is active or passive, registered or unregistered, paid or unpaid.

A "Minor" refers to any individual below the age of eighteen (18) years.

A "Child" refers to any individual below the age of thirteen (13) years.

"User Content" is intentionally defined broadly and inclusively to cover all possible forms of user-generated input. This includes, without limitation, videos, audio recordings, images, photographs, text, captions, hashtags, comments, replies, likes, reactions, shares, reposts, follows, subscriptions, direct messages, livestreams, profile information, metadata, interaction signals, and any other form of content, data, or expression generated, uploaded, transmitted, or displayed by a User through the Services.

"Personal Data" means any data or information, whether true or not, relating directly or indirectly to an identifiable individual, including data regulated under Indonesian Personal Data Protection Law (PDPA), the General Data Protection Regulation (GDPR), and any other applicable data protection or privacy laws worldwide.

"Interaction Data" refers specifically to behavioral and engagement data generated when Users interact with the Services, including viewing duration, scrolling behavior, comments, likes, shares, follows, subscriptions, saves, and similar engagement activities.

"Force Majeure" refers to any event or circumstance beyond the reasonable control of Soplè, including but not limited to natural disasters, acts of God, war, terrorism, riots, pandemics, epidemics, governmental actions, power outages, server failures, system crashes, cyberattacks, hacking incidents, telecommunications failures, or failures of third-party infrastructure providers.

2. Platform Status, Role & Legal Positioning

Soplè operates strictly as a global technology platform and online intermediary. The Services are designed to provide technical infrastructure that enables Users to create, upload, share, view, download, and interact with short-form digital content.

Soplè does not create, originate, author, edit, curate, verify, approve, endorse, and/or control User Content. Soplè does not act as a publisher, broadcaster, editor, journalist, or speaker in respect of any User Content. All User Content is created solely by Users, and responsibility for such content rests entirely and exclusively with the User who generated or interacted with it.

This distinction is fundamental and material. Users expressly acknowledge that Soplè’s role is limited to providing a neutral technological platform and that Soplè does not assume any responsibility for the substance, legality, accuracy, and/or consequences of User Content and/or interactions.

3. Time Is of the Essence, Service Availability & Force Majeure

Time is of the essence in relation to the performance of this Agreement. However, Users expressly acknowledge and agrees that uninterrupted, error-free, or continuous availability of the Services is not guaranteed.

The Services may experience delays, interruptions, downtime, data loss, or degradation of performance due to maintenance, upgrades, server issues, third-party failures, network congestion, or Force Majeure events. Soplè shall not be liable for any losses, damages, and/or inconveniences arising from such events.

In the event of Force Majeure, Soplè’s obligations under this Agreement shall be suspended for the duration of the Force Majeure event, and no liability shall attach to Soplè as a result.

4. Acceptance of Risk & User Assumption of Liability

By using the Services, Users knowingly and voluntarily accept that online platforms inherently carry risks. These risks include, without limitation, exposure to offensive, explicit, misleading, unlawful, defamatory, and/or harmful content; interactions with other Users that may result in disputes, harassment, and/or emotional distress; and reliance on information that may be inaccurate or incomplete.

Users expressly assume all such risks and agree that they use the Services entirely at their own risk. To the fullest extent permitted by law, Users irrevocably waive, release, and discharge Soplè from any and all claims, demands, causes of action, and/or liabilities arising out of and/or related to their use of the Services.

5. Information We Collect

Soplè collects, processes, and uses information relating to Users through multiple channels and in multiple forms. For the avoidance of doubt, Users expressly acknowledge that information is collected in three principal ways:

(i) information voluntarily provided by Users;

(ii) information automatically collected through the use of the Services; and

(iii) information obtained from third-party or external sources. Each category is explained in detail below.

5.1 Information You Provide Voluntarily

When a User creates an account, uploads or interacts with content, communicates with other Users or with Soplè, engages with AI-powered features, makes purchases, or otherwise uses the Services, the User may voluntarily provide certain information. Such information may include, without limitation, account registration details such as date of birth, username, password, email address, telephone number, and profile image.

Users may also provide extensive User Content, including comments, photographs, audio recordings, videos, livestreams, captions, and text. Users acknowledge that even where an individual is not a registered User, information relating to that individual may nevertheless appear within User Content uploaded by others. Soplè may technically collect User Content at the point of creation, import, or upload, including pre-publication processing, for the purposes of enabling platform functionality such as audio recommendations, visual effects, caption generation, personalization, moderation tooling, analytics, and content optimization, regardless of whether such content is ultimately published or saved by the User.

Users may further provide information through messaging features, including private messages, chat communications, and messages exchanged in connection with marketplace or shopping features. Where Users interact with AI-powered interfaces, Soplè may collect AI interaction data, including prompts, questions, files, instructions, and system-generated responses, for the purposes of operating, improving, and safeguarding such systems.

Where enabled by device permissions, Soplè may access clipboard content, including text or images, when Users intentionally use features that require copying, pasting, or sharing content with third-party services. Users further acknowledge that purchase-related information may be collected when transactions are conducted through the Services, including payment card details, billing information, delivery information, contact details, and transaction histories. Such information may be processed by third-party payment processors.

With express permission, Users may allow Soplè to access phone book data or social network contacts. This may include names, phone numbers, email addresses, and social graph information, which may be used to suggest connections, identify existing Users, or facilitate social features. Soplè may also collect information relating to account settings, communication preferences, identity or age verification documentation, correspondence with customer support, and information provided through surveys, advertising forms, research initiatives, promotions, marketing campaigns, events, or contests.

Users expressly acknowledge that information voluntarily provided may include sensitive personal data as defined under applicable privacy laws, including information relating to minors, racial or ethnic origin, nationality, religious beliefs, health information, sexual life or orientation, financial data, citizenship, or immigration status. Such information is provided at the User’s discretion and processed in accordance with applicable law.

5.2 Automatically Collected Information

When Users access or use the Services, certain information is collected automatically through technological means. This includes usage information such as interaction patterns, viewing behavior, engagement with advertisements, duration and frequency of use, and interactions with other Users or third-party websites accessed through in-app browsers.

Soplè also automatically collects technical information from the User’s device, network, and application environment. This may include IP address, user agent, mobile carrier, time zone, advertising identifiers, device model, operating system, network type, screen resolution, application and file identifiers, keystroke patterns or rhythms, battery state, audio settings, and connected peripheral devices. Soplè may assign device IDs or user IDs and may use such identifiers to recognize activity across devices or sessions.

Location information may also be collected, including approximate location derived from IP address, SIM card region, or system settings, as well as precise location information where Users enable location services. Users may choose to attach location data to User Content, such as tagging points of interest or venues. Location services may be disabled at any time through device settings.

Soplè may further collect information regarding content characteristics and features, including the identification of objects, scenery, faces, body parts, or audio elements within User Content, as well as transcribed text of spoken words. Such processing may involve biometric identifiers or biometric information (such as faceprints or voiceprints) where permitted by law and subject to required consents.

Metadata is also automatically generated and collected in connection with User Content, messages, or AI interactions. Metadata may include information regarding how, when, where, and by whom content was created, sent, or modified, as well as usernames or identifiers linking content to a specific account.

Cookies, pixels, SDKs, web beacons, and similar technologies may be used by Soplè and its partners to enable functionality, analyze usage, improve performance, deliver advertising, measure effectiveness, and promote the Services. Users may manage or restrict such technologies through device or browser settings, subject to functional limitations.

5.3 Information From Other Sources

Soplè may receive information from third-party sources where Users choose to connect external services to the Services. This may include public profile information or email addresses obtained through third-party login providers such as Google, Facebook, or Apple.

Soplè may also receive information from advertisers, publishers, analytics providers, and measurement partners regarding User activity outside the Services, including pages visited, products purchased, or applications downloaded. Such partners may provide advertising identifiers, hashed contact details, or cookie-based data to facilitate advertising measurement and delivery.

Information may further be obtained from sellers, payment processors, and transaction fulfillment providers in connection with purchases conducted through marketplace features. Soplè may also receive information from affiliated entities under common control, from other Users where a User is referenced or mentioned in content or complaints, and from professional organizations, businesses, governmental authorities, or publicly available sources.

6. Data Processing, AI Systems & Purpose Limitation

Personal Data and other information collected are processed for purposes including operation and maintenance of the Services, personalization and recommendation algorithms, AI system training and improvement, advertising and monetization, fraud prevention, security, analytics, research, and legal compliance.

AI-generated outputs are automated and provided without warranty. Users remain solely responsible for how they interpret or rely on AI interactions.

7. Data Sharing, Disclosure & International Transfers

Soplè may share, disclose, or make available information collected from Users strictly in accordance with this Agreement and for legitimate operational, commercial, legal, and/or security-related purposes.

Information may be shared with service providers and business partners who perform functions on behalf of Soplè, including but not limited to hosting, cloud infrastructure, data storage, disaster recovery, analytics, advertising delivery, marketing services, communications, customer support, payment processing, transaction fulfillment, and fraud detection. Such parties are authorized to process information only as necessary to perform their designated functions.

In the event of any merger, acquisition, consolidation, restructuring, financing, reorganization, or sale of assets or shares, User information may be disclosed or transferred as part of the transaction. Users acknowledge that such transfers are a legitimate business necessity and consent to the same.

Soplè may further disclose information where required to comply with applicable laws, regulations, court orders, subpoenas, governmental requests, or law enforcement demands, or where disclosure is reasonably necessary to protect the rights, property, safety, or security of Soplè, its Users, or the public.

Depending on privacy settings and the nature of the Services, User Content and certain account information may be visible to other Users or the public and may be indexed by search engines or accessed through third-party platforms. Users acknowledge that Soplè bears no responsibility for information that Users choose to make publicly available.

Soplè may also share limited, aggregated, anonymized, or de-identified information with independent researchers or academic institutions for legitimate research purposes, subject to appropriate safeguards.

All sharing and disclosure may involve international data transfers. Users expressly consent to the storage, processing, and transfer of their information to any jurisdiction worldwide where Soplè or its service providers operate, regardless of differences in data protection standards.

8. User Rights, Choices & Other Statutory Rights

Subject to applicable law, Users may have certain rights in relation to their Personal Data, including the right to request access to, correction of, or deletion of such data. Users may also deactivate or delete their accounts through available in-app settings or by contacting Soplè.

Users may manage cookies through browser or device settings, manage advertising preferences within account settings, opt out of marketing communications using provided unsubscribe mechanisms, and control device-level permissions such as access to contacts, camera, microphone, or location services.

Soplè will not discriminate against Users for exercising statutory rights; however, Users acknowledge that the exercise of certain rights may result in limited functionality or unavailability of certain features of the Services.

Sharing for Direct Marketing Purposes

Depending on the User’s jurisdiction, Users may be entitled, no more than once per calendar year, to request information regarding whether Soplè has shared Personal Data with third parties for their own direct marketing purposes. Any such request must be submitted through the designated Contact Us channels and will be processed in accordance with applicable law.

9. Children, Minors & Parental Responsibility

The Services are not designed for Children under the age of thirteen (13) unless permitted by applicable law and accompanied by verifiable parental consent. Minors between thirteen (13) and eighteen (18) years of age may use the Services only with parental or legal guardian consent.

Parents and guardians acknowledge full responsibility for a Minor’s use of the Services and agree to indemnify Soplè from any claims arising therefrom.

10. User Content, Interactions, Prohibited Reliance & Creator Payments

Users retain ownership of their User Content; however, by uploading or making available User Content through the Services, Users grant Soplè a perpetual, irrevocable, worldwide, royalty-free, transferable, and sublicensable license to use such content for the operation, improvement, distribution, promotion, monetization, and commercial exploitation of the Services.

Users expressly agree not to rely on any User Content, comments, likes, shares, follows, subscriptions, and/or algorithmic distribution as accurate, complete, safe, endorsed, or approved by Soplè. Any reliance is strictly at the User’s own risk.

Creator Payments, Incentives & Monetization Programs

From time to time, Soplè may, at its sole and absolute discretion, introduce creator incentive programs, revenue-sharing arrangements, bonuses, rewards, advertising revenue distributions, or other forms of payments to Users who upload or publish User Content (collectively, "Creator Payments").

Users expressly acknowledge and agree that:

(a) Participation in any Creator Payments program is entirely optional and subject to eligibility criteria, verification requirements, geographic limitations, content standards, performance thresholds, and internal policies determined solely by Soplè;

(b) Soplè has the unrestricted right to determine whether, when, how, and in what amount any Creator Payments are made, and may modify, suspend, withhold, delay, reduce, claw back, and/or terminate any Creator Payments program at any time, with or without notice, and without liability;

(c) No User is entitled to Creator Payments as of right, and the existence of User Content, views, likes, shares, subscriptions, and/or engagement metrics does not create any obligation on the part of Soplè to make payment;

(d) Creator Payments, if any, do not constitute wages, employment income, partnership profits, agency fees, and/or any form of guaranteed compensation, and no employment, partnership, joint venture, or agency relationship is created between Soplè and any User;

(e) Soplè shall not be liable for any loss of income, loss of opportunity, expectation damages, and/or reliance damages arising from changes to, suspension of, or termination of any Creator Payments program;

(f) Users are solely responsible for all taxes, duties, reporting obligations, and compliance with applicable laws arising from any Creator Payments received;

(g) Any disputes relating to Creator Payments shall be resolved exclusively in accordance with the dispute resolution provisions of this Agreement, and Users expressly waive any right to bring claims, actions, or proceedings against Soplè in respect of unpaid, delayed, reduced, or discontinued Creator Payments.

11. Sexual Content, Harassment, Threats, Warnings & Criminal Offences Disclaimer

Users expressly acknowledge that the Services are user-driven and may be misused for unlawful purposes. Soplè does not encourage, support, facilitate, and/or condone any criminal activity.

Without limitation, Soplè shall not be responsible and/or liable for any User Content, conduct, communication, transaction, or interaction involving or constituting:

(a) sexual offences, exploitation, grooming, pornography, or obscene material;

(b) harassment, stalking, intimidation, threats, coercion, or hate crimes;

(c) fraud, scams, impersonation, identity theft, phishing, or financial crimes;

(d) money laundering, terrorism financing, or organized criminal activity;

(e) drug-related offences, sale or promotion of illegal substances;

(f) weapons-related offences, violence, or incitement to violence;

(g) child abuse, child exploitation, or any offence involving minors;

(h) cybercrimes, including hacking, unauthorized access, malware distribution, or denial-of-service attacks;

(i) defamation, blackmail, extortion, or unlawful surveillance;

(j) infringement of intellectual property rights or trade secrets;

(k) violations of immigration, employment, tax, or regulatory laws;

(l) any other criminal offence under the laws of any jurisdiction.

All criminal acts, allegations, investigations, prosecutions, penalties, and liabilities arising from such conduct shall be the sole responsibility of the offending User. Soplè expressly disclaims any duty to investigate, prevent, and/or enforce against criminal conduct, save where required by mandatory law.

Soplè reserves the right, but has no obligation, to cooperate with law enforcement authorities, disclose information, or take action where legally required or where necessary to protect its rights, Users, or the public. Such cooperation does not create any duty of care and/or liability.

12. Data Security & Retention

Soplè implements reasonable administrative, technical, and physical safeguards designed to protect Personal Data against unauthorized access, disclosure, alteration, or destruction. Notwithstanding such measures, Users acknowledge that no system, network, or method of electronic transmission is completely secure, and Soplè cannot and does not guarantee absolute security.

Personal Data is retained only for as long as reasonably necessary to provide the Services, comply with legal obligations, resolve disputes, enforce agreements, protect legitimate business interests, and maintain records for regulatory or audit purposes. Retention periods vary depending on the nature of the data, the purposes of processing, and applicable legal requirements.

Subject to applicable laws, Personal Data may be stored, processed, or accessed outside the User’s country of residence in jurisdictions where Soplè or its service providers maintain operations.

13. Disclaimer of Warranties

The Services are provided on an "AS IS" and "AS AVAILABLE" basis, without warranties of any kind. Soplè expressly disclaims all warranties, whether express, implied, or statutory.

14. Limitation of Liability

To the maximum extent permitted by law, Soplè shall not be liable for any indirect, incidental, consequential, special, exemplary, or punitive damages. Soplè’s total aggregate liability shall not exceed USD 10 or the total fees paid by the User in the preceding twelve (12) months, whichever is higher.

15. Indemnity

Users agree to fully indemnify, defend, and hold harmless Soplè, its directors, officers, employees, developers, agents, contractors, and service providers from all claims, losses, liabilities, damages, costs, and legal fees arising from User Content, interactions, or use of the Services.

16. Directors, Employees, Agents & Developers Immunity

No personal liability shall attach to any director, officer, employee, developer, agent, or contractor of Soplè under any circumstances.

17. Jurisdiction-Specific Laws, Local Compliance & Governing Law

Notwithstanding the global nature of the Services and the governing law and arbitration provisions set out in this Agreement, Users expressly acknowledge and agree that certain countries, states, or jurisdictions impose mandatory legal requirements, public policy rules, or consumer protection laws that may apply based on the User’s location, nationality, or place of residence.

Where a User accesses or uses the Services from a particular jurisdiction, that User is solely responsible for ensuring that their use of the Services, including the creation, upload, sharing, viewing, monetization, or interaction with User Content, complies with all applicable local laws, regulations, legal principles, and regulatory requirements of that jurisdiction.

Soplè does not represent or warrant that the Services or any User Content are lawful, appropriate, or available for use in every jurisdiction. Access to or use of the Services may be restricted, limited, or prohibited by law in certain countries, and Users who access the Services from such jurisdictions do so entirely at their own risk.

Nothing in this Agreement shall be construed as an undertaking by Soplè to comply with or enforce the laws of every jurisdiction worldwide. To the maximum extent permitted by law, Soplè disclaims any liability arising from a User’s failure to comply with local legal requirements.

Where mandatory laws of a User’s jurisdiction require the application of specific legal protections that cannot be contractually excluded, such laws shall apply only to the minimum extent required, and solely in respect of that User. All other provisions of this Agreement shall remain in full force and effect.

Subject always to the foregoing, this Agreement shall otherwise be governed by the laws of England & Wales, and all disputes shall be resolved exclusively through binding international arbitration seated in England & Wales, as set out herein.

18. Privacy Policy Updates, Modifications & No-Notice Changes

Soplè may update, amend, and/or modify this Agreement, including its privacy-related provisions, from time to time. When material changes are made, Soplè may notify Users by updating the “Last Updated” date at the top of this Agreement, posting the revised version on the Services, or providing any additional notice required by applicable law.

Users are encouraged to review this Agreement periodically to remain informed about how Soplè collects, uses, processes, and protects information. Continued use of the Services following any update constitutes acceptance of the revised Agreement.

Where permitted by applicable law, certain changes may be implemented without prior notice to Users.

19. Additional Legal Safeguards & Risk Mitigation Clauses

Severability

If any provision of this Agreement is held to be invalid, illegal, or unenforceable by a court or arbitral tribunal of competent jurisdiction, such provision shall be severed and modified to the minimum extent necessary to render it enforceable, and the remaining provisions of this Agreement shall continue in full force and effect.

No Class Action or Representative Proceedings

Users expressly waive any right to bring and/or participate in any class action, collective action, representative action, or private attorney general action against Soplè. All claims must be brought on an individual basis only.

Limitation Period for Claims

Any claim, cause of action, or dispute arising out of or relating to the Services or this Agreement must be commenced within six (6) months from the date the claim arose, failing which such claim shall be permanently barred.

Export Control & Sanctions Compliance

Users represent and warrant that they are not located in, organized under the laws of, or subject to sanctions imposed by any country, authority, or regime that restricts the provision or receipt of services under applicable export control or sanctions laws. Users agree not to use the Services in violation of any such laws.

No Professional Advice Disclaimer

All content, AI outputs, information, and materials made available through the Services are provided for general informational purposes only and do not constitute legal, financial, medical, investment, or professional advice. Users rely on such information entirely at their own risk.

Recording, Consent & Third-Party Rights

Users represent and warrant that they have obtained all necessary consents, permissions, and authorizations from any individual whose image, voice, likeness, or personal data appears in User Content. Soplè shall not be liable for any failure by Users to obtain such consent.

Government Requests & Non-Notification

Where required by law or authority, Soplè may disclose User information to governmental or law enforcement authorities without prior notice to the User. Users waive any claim arising from such disclosure.

Survival of Obligations

Provisions relating to intellectual property, licenses, limitation of liability, indemnity, dispute resolution, governing law, waivers, and this section shall survive termination or suspension of a User’s account or access to the Services.

Assignment

Soplè may assign, transfer, or novate this Agreement, in whole or in part, without notice to or consent from Users. Users may not assign their rights or obligations without Soplè’s prior written consent.

Entire Agreement

This Agreement constitutes the entire agreement between Users and Soplè regarding the Services and supersedes all prior or contemporaneous agreements, representations, or understandings, whether written or oral.

20. Final Acknowledgement & Release

By clicking "Agree" or otherwise using the Services, Users confirm that they have read, understood, and voluntarily accepted this Agreement in its entirety, assume all risks associated with the Services, and irrevocably waive and release Soplè from liability to the maximum extent permitted by law.