Sargam Privacy Policy

This Privacy Policy ("Privacy Policy") describes the privacy practices that we, StarMaker Entertainment Technology India Limited ("Sargam" or "We"), employ with regard to collecting, using and disclosing information, both personal and non-personal information, which we receive when you use our Services. When we say "Services" in this Privacy Policy, we mean the "Services" as defined in our Terms of Service, accessible at https://m.melodistudios.com/webview/v17/terms/index-in.html and via our mobile device applications. This Privacy Policy applies only to those websites, services and applications included within "Services" and doesn't apply to any third-party websites, services, or applications, even if they are accessible through our Services. By using the Services you consent to the collection, processing, dealing, handling, transfer, use, storage, disclosure and sharing of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH THE PRACTICES EXPLAINED IN THIS PRIVACY POLICY, DO NOT ACCESS, BROWSE OR USE THE SARGAM SERVICES.

We are committed to safeguarding any personal information collected through the Services. This Privacy Policy is intended to inform you of our policies and procedures regarding the collection, processing, dealing, handling, transfer, storage, use, sharing and disclosure of information on our Services. We also want to inform you about your choices regarding information you share with us. If you have any questions or concerns, please let us know (see "How to contact us" section below).

Unless otherwise defined in this Privacy Policy, capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible at https://m.melodistudios.com/webview/v17/terms/index-in.html. As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

How We Collect Info

We collect info in the following ways:

What Information We Collect and How We Use It:

Personal Information:

We collect personally identifiable information ("Personal Information", or "PII") directly from you when you create an Account. Personal information is information that identifies you and may be used to contact you either online or offline. Personal Information may include, but is not limited to, your profile photo/audio/video, stage name, audio recordings, video recordings, passwords, phone number and email address. Additionally, if you register using a valid SNS account, we use the Personal Information you have already provided to the SNS (such as your "real" name, email address and other information you make publicly available on the SNS as well as additional information you've provided specific permission to Sargam to access via the SNS) to create your Account on our Services; the information we collect may depend on the privacy settings you have with the SNS, so please consult the SNS's privacy and data practices. For example, by using Facebook Connect, you are allowing Sargam to access the Personal Information in your Facebook account pursuant to the Facebook Terms of Use regarding your use of the Services via Facebook. If authorized by you, we may also access your profile and other information from SNS, like Facebook.

Sensitive Personal Information

We may collect information about the images that are a part of your User Content or you are making the livestream, such as detecting or identifying the objects and scenery that appear, the existence and location within an image of face and body features and attributes, and the text of the words spoken in your User Content. We may collect this information to protect the rights and safety of the children users and keep the content uploaded or streamed in the Service to be in compliance with the laws and regulations. We may collect biometric identifiers and biometric information as defined under your local laws, such as faceprints, from your User Content. Where required by law, we will seek any required permissions from you prior to any such collection. As for the biometric information collected from you, we will not disclose it to any third party and will not use it for any other purpose, and we will delete it within [180] days.

We use your Personal Information and Sensitive Personal Information (in some cases, in conjunction with your "Non-Identifying Information", see below) (collectively referred as "Information") to provide the Services to you. For example:

Account registration:

We create your Account for your use of the Services based upon the Personal Information you provide.

Communications:

We may use your Personal Information to contact you with Sargam newsletters, marketing or promotional materials and other information that may be of interest to you. 

Customer service:

We use your Personal Information to respond to your questions and/or inquiries. 

Audio & Video Content

As part of our Services, we collect and store the audio and video recordings that you choose to make and post within the Apps while signed into your Account. We do not store or collect audio or video recordings made within the Apps that are not connected with a valid, signed-in Account. Audio and video recordings that are uploaded to the Services are set to "public" by default, which means that anybody using the Services can view them. You can change your privacy settings to make an audio or video recording "private", in which case only other Account holders with whom you've shared a link to such audio or video recording will be able to access it. You can also delete an audio or video recording from your Account on the Services. Deleting an audio or video recording will prevent anyone (including you) from accessing the audio or video recording; however, Sargam may retain an archived copy.

Non-Identifying Information

We also collect other information that you provide as part of registration, the operation, and personalization of your Account that cannot reasonably be used to identify or contact you (e.g., individual preferences) ("Non-Identifying Information"). Certain Non-Identifying Information would be considered a part of your Information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be personally identified or contacted. But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other Non-Identifying Information (for example, your viewing preferences).

We may combine your Information with Non-Identifying Information and aggregate it with information collected from other Sargam users to attempt to provide you with a better experience, to improve the quality and value of the Services and to analyze and understand how our Services are used. We may also use the combined information without aggregating it to serve you specifically, for instance to deliver a product to you according to your preferences or restrictions.

Log Data:

Our servers automatically record certain information about how a person uses our Services, including both Account holders and non-Account holders ("Log Data"). This Log Data may include information such as the browser type or the webpage you were visiting before you came to our Services, pages of our Services that you visit, the time spent on those pages, information you search for on our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and the Services' technical administration, to increase our Services' functionality and user-friendliness, and to better tailor our Services to our visitors' needs. For example, some of this information is collected so that when you visit the Services again, it will recognize you and the information could then be used to serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Services meet the criteria required to process their requests.

Cookies:

Like many online services, Sargam uses "cookies" on our Services to collect information. A cookie is a small data file that your browser transfers to your computer. We use cookies for two purposes. First, we utilize "persistent" cookies to save your login information for future logins to the Services. Second, we utilize "session ID" cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by Sargam Users and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser.

Google and Facebook Analytics

We use Google Analytics and Facebook Analytics to collect information about use of the Services. Google Analytics and Facebook Analytics collect information such as how often users visit the Services, what activities do they do when they visit the Services, and what are the locations when they login the Services. We only collect aggregate information through Google Analytics and Facebook Analytics, for the purpose of copyright royalty calculation, marketing event implementation, and tailored service provision for users in specific territory.  It is necessary for our cooperation with music licensors to provide high quality music services to our users.  IF YOU DO NOT AGREE WITH THE PRACTICES EXPLAINED IN THIS SECTION, DO NOT ACCESS, BROWSE OR USE THE SARGAM SERVICES; OR, DELETE THE APP FROM YOUR MOBILE DEVICE AND TERMINATING ALL OTHER USES OF THE SERVICE, IF YOU ALREADY HAD REGISTED WITH OUR SERVICE.

Sharing of your information

Your Information will be shared or disclosed for the purposes as mentioned in this Privacy Policy and to such third parties only with your consent as provided at the time of signing up/ logging in. Please note that such third parties may further disclose this information and you hereby consent to such disclosure.

Sargam Audio and Video Recordings and Account Information:

When you register through the Services and submit Personal Information to create a profile, this information will represent you if you choose to share the audio and video recordings you create on the Sargam platform. Your profile image, stage name, and the audio and video recordings that you have chosen to share, will be publicly accessible.

Information Shared with Third Parties:

We may share aggregated information that does not include Information and we may otherwise disclose Non-Identifying Information and Log Data with third parties for industry analysis, demographic profiling and other purposes. Any aggregated information shared in these contexts will not contain your Information. We may also provide your Information to our business partners or other third parties for the purpose of providing you with information on goods or services we believe will be of interest to you. 

Share Your Personal Information With YouTube

If you use the content or service provided by YouTube, you agree to share your Personal Information with YouTube. It is a must for you to abide by [Terms of Service (youtube.com)] and [Privacy Policy – Privacy & Terms – Google] (collectively, the “YouTube Terms”) and you confirm that you are consent to be the User of YouTube with acceptance of all the YouTube Terms before you use the content or service provided by YouTube. Meanwhile, you agree to allow Sargam to share your personal information (including without limitation name, location, telephone number, operating system, IP address, etc.) with YouTube or allow YouTube to collect your personal data as stipulated in the YouTube Terms when you are using the content or service provided by YouTube.

You can obtain the YouTube Terms through the following two ways:

  1. Click the said hyperlink of each YouTube Term aforesaid;
  2. Click the following links:

(i) For YouTube Terms of Service

https://www.youtube.com/t/terms

(ii) For YouTube Privacy Policy

http://policies.google.com/privacy?hl=en

Service Providers:

We may employ third party companies and individuals to facilitate our Services, to provide the Services on our behalf, to perform Services-related services (e.g., maintenance services, database management, analytics and improvement of the Services features) or to assist us in analyzing how our Services are used. These third parties have access to your Information only to perform these tasks on our behalf.

Social Networking Sites:

We may share the information in your Account (including your Information) with the SNSs that you have linked to your Account.

Facebook Connect:

You may share your recent activity on our Services back to your Facebook account. You will be prompted to decide whether or not your activity on the Services will be shared and disclosed on your Facebook service. We will not otherwise share content, videos, or other Account information to your Facebook account without your authorization.

Compliance with Laws and Law Enforcement:

Sargam cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We can disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process including, but not limited to, subpoenas, to protect the property and rights of Sargam or a third party, to protect the safety of the public or any person, to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity, or if it is required by law.

Business Transfers:

Sargam may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our assets, including any or all of the information described in this Privacy Policy, in the course of a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding.

Your choices regarding information

You have several choices regarding the use of information on our Services:

Your Audio and Video recordings:

You have control over whether to save and upload your audio and video recordings to the Services. We give you tools to send a link to the audio or video recording that resides on our Services.

Communications:

If you decide at any time that you no longer wish to receive communications from us, please follow the unsubscribe instructions provided in any of the communications or update your "preferences" information in your Account settings. As part of providing you the Services, we may need to provide you with certain notifications and communications, such as service announcements and administrative messages. These communications are considered part of the Services and your Account, which you may not be able to opt-out from receiving. If you have any questions about how to unsubscribe communications or update preferences, please let us know at the contact information provided below.

Cookies:

If you decide at any time that you no longer wish to accept cookies from our Services for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Consult your browser's technical information. If you do not accept cookies, however, you may not be able to use all portions of the Services or all functionality of the Services. If you have any questions about how to disable or modify cookies, please let us know at the contact information provided below.

Additional Information:

We may also use certain additional information from you to help improve and personalized you experience across our Services. You may choose to share your location with Sargam, or we may determine your location by using other data from your device, and such location information may help us to precisely provide you certain features of our services. You will be asked to allow us to collect your location information. If you decide that you no longer want us to collect your location information, you can go to your device’s setting page and disable location service for our Services. Also, you may choose to upload and sync your address book so that we can help you find and connect with users you know or help other users find and connect with you. You will be given an opportunity to make a choice before you decide to share your address book with us. If you decide not to share your address book anymore, you can disable the feature by visiting the Setting page of your phone. 

Changing or Deleting Your Information:

All Account holders may review, update, correct, delete or withdraw their consent for processing of the Information in their Account by contacting us or by editing their profile via the Services. With respect to recordings made through the Services: You can change your privacy settings to make an audio or video recording "private", in which case only other Account holders with whom you've shared a link to such audio or video recording will be able to access it. Account holders can also delete an audio or video recording from the Services, which will prevent anyone (including you) from accessing the audio or video recording; however, Sargam may retain an archived copy on its servers for as long as required under the applicable laws and regulations. 

How we store and protect information

Retention

The information above would be collected and retained by the following entity-

StarMaker Entertainment Technology India Limited.

SECTOR 54 GURGAON,

GURGAON HARYANA - 122002

We will not retain any sensitive personal data or information for longer than is required for the purpose for which such data or information was collected or may lawfully be used or is otherwise required under any other law for the time being in force. We will retain the Personal Information for a minimum period of 180 days or as required under applicable laws. We may retain anonymized/ deidentified data for as long as is required.

Information Security:

We care about the security of your information. We implement reasonable physical, technical and administrative security standards designed to protect your Information from loss, misuse, alteration, destruction or damage and to ensure a level of security appropriate to the risk, and such security standard will be at an equivalent or higher level than the international standard IS/ISO/IEC 27001 on "Information Technology - Security Techniques - Information Security Management System - Requirements". However, we cannot ensure or warrant the security of any information you provide to us or guarantee that information on the Services may not be accessed, disclosed, altered, or destroyed by unauthorized persons.

Phishing:

Identity theft and the practice currently known as "phishing" are of great concern to Sargam. Safeguarding information to help protect you from identity theft is a top priority. We do not request your credit card information, login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.

Breach Notification:

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer:

Your information may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside India and choose to provide information to us, Sargam transfers Information to the India and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

If you are an Indian resident, in respect of such transfers, we will ensure that your Information receives the same or higher level of protection as required under Indian data protection laws.

Do Not Track Disclosures

Our Services are not set up to respond to Do Not Track ("DNT") signals. We use third party service providers like Google Analytics for tracking purposes.

Links to Other Sites

Our Services may contain links to other websites and services. Any information that you provide on or to a third-party website or service is provided directly to the owner of the website or service and is subject to that party's privacy policy. Our Privacy Policy does not apply to such websites or services and we're not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information we recommend that you carefully review the privacy policies of other websites and services that you access.

Credit card payments, including recurring charges such as charges for subscriptions to the Service, are handled through Apple and Google, or other third party payment processors. Apple and Google will collect and may retain your credit card information in order to process your payment, including payment for your purchases of subscriptions or for any Service charges. We do not control this third party collection, use, disclosure, or retention of your information. Please review Apple's and Google's privacy policy and terms of use prior to submitting your payment information.

Our Policy Toward Children:

Our Services are NOT directed to children under 13, and we do not knowingly collect PII from children under 13. We take extra steps to ensure that users creating Accounts are 13 or older. If you are above 13 and below 18, you guarantee that you’ve got the consent of your parent or legal guardian, and your parent or legal guardian agree Sargam to collect Information from you without further getting the consent of your parent or legal guardian. We encourage parents to take precautions to assure that their household is safe and protected when the children creating and sharing the video content.

For children user who pretends to be an adult and use the adult-age to register the Service or the children user who borrows adult accounts to use the Service, we may collect the personal information of the children user as an adult user since we cannot realize that the user is a child before we detect and identify him or her as a child. If we detect and identify the user is a child, we will block the user account and forbid the user to use the Service.

For Children Users:

What Information We Collect?

We collect information based on your use of the Sargam, like when a children user makes the registration of the Sargam, listening a sound recording, watching a video, watching a live steaming, or join the chatting room, etc. This information includes:

(a) user name, age, or other profile information will include your real name or nick name, month of birth if you choose to provide it;

(b) the audio recordings, or other contents uploaded by you to Sargam;

(c) device type and settings, such as hardware model and operating system version;

(d) log information, including details of how our service is used, device event information, and the device's Internet protocol (IP) address;

(e) the pictures, text or other documents you posted in Sargam;

(f) collect biometric identifiers and biometric information as defined under India laws, such as faceprints when a children user pretending an adult to make live streaming;

(g) unique application numbers, such as application version number; and

(h) unique identifiers, which are used to collect and store information about an app or device, such as preferred language, app activity, and other settings.

How Do We Use the Information We Collect?

(a) We use the information we collect for internal operational purposes such as for spam and abuse prevention, determining preferred language, providing, supporting and improving the service;

(b) We perform analytics and troubleshoot; protect the security or integrity of the user and our service; and ensure legal or regulatory compliance;

(c) The App do not allow you to share personal information with third parties or make it publicly available, and the App does not allow interest-based advertising or remarketing to you;

(d) to protect the children’s privacy and interests; and ensure legal or regulatory compliance regarding children protection.

How Do We Share the Information We Collect?

We share the information we collect with our corporate group and with service providers as necessary for them to perform a business purpose, professional service, or technology support function for us.

We may disclose personal information if permitted or required by law:

(a) in response to a court order or a subpoena;

(b) in response to a law enforcement or public agency’s (including schools or children services) request;

(c) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of Children Users using our sites or applications;

(d) to protect the security or integrity of our sites, applications, and other technology, as well as the technology of our service providers; or

(e) enable us to take precautions against liability.

Changes

Any information that is collected is subject to the Privacy Policy in effect at the time such information is collected. We may, however, modify and revise our Privacy Policy from time-to-time. If we make any material changes to this policy, we will notify you of such changes by posting a new Privacy Policy and updating the "last modified" date at the top of this page or by sending you an email or other notification, and we will indicate when such changes will become effective. By continuing to access or use the Services after those changes become effective, you are agreeing to be bound by the revised policy.

How to contact us

If you have any questions or grievances about this Privacy Policy or any of the practices described herein, please contact us at: appsupport@melodistudios.com 
or

Grievance Officer Name/ Data Protection Officer: Sleeja Misra

Address: SECTOR 54 GURGAON, GURGAON HARYANA - 122002

GOVERNING LAW

These Terms of Service and any separate agreements whereby we provide you Services shall be governed by and construed in accordance with the laws of India

Last updated: Apr 1st, 2021