JAZZSMART DATA POLICY

effective 23/05/2022

This Data Policy (“Policy”) describes how Novelty Media Services Ltd., in its capacity of personal data administrator, collects, uses and discloses personal information of users of JazzSmart app, in its version developed in cooperation with Pakistan Mobile Communications Limited (JAZZ) – “JazzSmart” (“the App”), as well as of the services offered through the App (“Services”).

The information submitted through the App is collected by NOVELTY as the application provider. By providing your information, you acknowledge and agree to such collection by NOVELTY. NOVELTY’s Data Policy governs the way the information collected through the App is used and further processed.

The privacy policy is available at https://smartadd.app/jazzsmart-data-policy/.

This Policy is subject to periodic review, of which you will be notified in advance through the App. Please also check the above website regularly. Continued use of the App or Services following submitted notice of such changes is considered as acknowledgement from your side of the respective changes and consent to be bound by the terms of such changes.

Contact details regarding personal data protection

Please direct all questions concerning the processing of your personal data to the Data Protection Officer at NOVELTY: pk.dpo@novelty-media.com.

1. What kinds of information do we collect?

A. YOUR PERSONAL PROFILE DATA

While signing-up to the Service, you are asked to create your personal profile (the “Account”). The Account includes a set of personal information, such as your date of birth, your gender, your relationship status, your location, and your most relevant interests (as a selection from a prefilled list).

We will not verify the validity of those data: it will be under your responsibility to provide them in the most accurate way possible, to enable us to deliver the most appropriate content to you.

B. YOUR USAGE OF THE SERVICE

We collect information about how you use our Service: for how long you watch content, your rating of the content you got exposed, the content you interacted with.

C. YOUR INPUTS TO SURVEYS/POLLS

From time to time, you might be displayed with dedicated surveys/polls about various topics, such as services you like the most, your level of satisfaction about the call center support of the Operator, and others. We process those data to elaborate marketing/caring statistics, and to enrich your Account with relevant information to improve your experience in Service.

D. YOUR MOBILE PHONE

We collect information from and about the mobile phone you installed the application on. Information we obtain from the device may include:

  • Device attributes: operating system, hardware and software versions, available storage space, app names.
  • Device operations: operations and behaviors performed on the device, such as number of unlocks and voice calls per hour executed in a day.
  • Identifiers: unique identifiers, device IDs, and other identifiers related to the application.
  • Network and connections: name of your mobile operator or ISP, language, time zone, mobile phone number.
  • Cookie data: data from cookies stored on your device, including cookie IDs and settings.

E. YOUR PROFILE AS CUSTOMER OF THE MOBILE NETWORK OPERATOR

We collect information about your mobile phone number from the Mobile Operator, such us when you activated your SIM card, your active products and tariff plans, your status on the Mobile Operator’s network, your customer segment.

F. INFORMATION FROM THIRD PARTIES

We may activate the collection of data from Third Parties cookies. In case we will activate the collection of data from Third Parties, you will be notified so to confirm your willingness to proceed using the Service under the new terms.

2. How do we use the data we collect?

We use the information we collected about you to:

A. CHOOSE THE KINDS OF CONTENT WE DISPLAY ON YOUR DEVICE

We address the content to your Account based on the data we collect. The content types and the time of their display are selected by our customer experience algorithms, and they are at our sole discretion. You may have the possibility to rate the content via the dedicated surveys we run from time to time, and/or “like” or “unlike” it via the dedicated capability (if available).

B. DELIVER ADVERTISMENT RELEVANT FOR YOU

We select and personalize commercials, offers and other sponsored content that we show you based on your location, interests, usage, and many other factors.

C. COMMUNICATE WITH YOU

We send you marketing and caring communications about the Service and inform you about our terms and policies of the Service. We also deliver to you socially relevant messages, and charitable initiatives.

D. PRODUCE USAGE AND MARKETING ANALYSIS

We collect information to conduct and support research and innovation on marketing based on the usage of the Service, the interaction with the displayed content, and the usage of the device.

3. How do we share this information?

Your information is shared with others in the following ways:

A. ADVERTISERS AND MEDIA AGENCIES

We provide advertisers and media agencies with reports about the performances of their marketing campaigns. Reports are made up of aggregated information to help understanding the audience we address. We don’t share information that personally identifies you.

Advertisers and Media Agencies may select to communicate to their customers by addressing marketing campaigns to a list of mobile phone numbers they own; we do not provide them with a list of mobile phone numbers active in Service, nor we are responsible to check if you gave them the consent to utilize your mobile phone number for commercial purposes.

B. MOBILE OPERATOR

We provide the Mobile Operator with data about your usage of the Service, including the benefits you have been granted with.

C. VENDORS AND SERVICE PROVIDERS

We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analysing how our Service is used, providing customer service, or conducting surveys.

4. How can you exercise your rights provided under the data protection legislation GDPR?

As per the data protection legislation organized under A)  Prevention of Electronic Crimes Act, 2016 and B) Personal Data Protection Bill 2021, you have the right to access, rectify, and erase your data. These capabilities are available in the dedicated screen of the application.

5. Data retention, account deactivation and deletion

We store data until it is no longer necessary to provide our Service, or until your account is deleted – whichever comes first.

Your account will be automatically deleted after 180 consecutive days of inactivity in Service. Upon account deletion, we won’t be able to recover that information later. If you don’t want to delete your account but want to temporarily stop using the Service, you can deactivate the application instead.

6. How do we respond to legal requests or prevent harm?

We access, preserve, and share your information with regulators, law enforcement or others:

  • In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards.
  • When we have a good-faith belief it is necessary to: detect, prevent, and address fraud, unauthorized use of the Service, violations of our terms or policies, or other harmful or illegal activity.

Information we receive about you can be accessed and preserved for an extended period when it is the subject of a legal request or obligation, governmental investigation, or investigations of possible violations of our terms or policies, or otherwise to prevent harm. We also retain information from accounts disabled for terms violations for at least a year to prevent repeat abuse or other term violations.

7. How will we notify you of changes to this policy?

Before we make changes to this policy, we will notify and give you the opportunity to review the revised terms within the JazzSmart app before you choose to continue using our Service.