Sinai Privacy Policy

This Privacy Policy ("Policy") explains how Sinai Ltd ("we," "us," "our") processes your personal data. It applies to your use of:

• All Sinai streaming services, including usage on any device.
• Personalization features that tailor the user experience.
• Infrastructure required to deliver our services.
• Integration of Sinai with third-party applications.
• Free and paid subscription options (each a "Service Option").
• Other Sinai services linked to this Policy, such as websites, customer support, and community forums.

Collectively, these will be referred to as the "Sinai Service."

From time to time, we may introduce additional services or features. These will also be governed by this Policy unless stated otherwise.

This Policy does not cover:

• The Sinai Terms of Use, which govern your legal agreement with us.
• Other Sinai services with separate privacy policies.

For more resources on managing your privacy:

• Privacy Center: A hub for key privacy information and tools to manage your settings.
• Account Privacy Settings: Adjust preferences for data usage and tailored advertising.
• Notification Settings: Manage your marketing communication preferences.
• Cookies Policy: Understand how we use cookies and manage your preferences.

Sinai respects your rights under privacy laws such as the General Data Protection Regulation (GDPR). These rights include:

Be Informed: Learn how we process your data via this Policy or by contacting us. You can read this Policy or contact us with questions.

Access: Request a copy of your personal data. Use the "Download your data" tool in Account Privacy or contact us.

Rectification: Request corrections to inaccurate or incomplete data. Update your profile in "Edit Profile" settings or contact us.

Erasure: Request deletion of personal data under specific conditions. Use available tools to remove data or contact us to request deletion.

Restriction: Request temporary or permanent cessation of certain data processing. Contact us to request restrictions.

Object: Object to processing for legitimate interests or tailored advertising. Adjust preferences in Account Privacy or contact us.

Data Portability: Request your data in a transferable format for another service. Contact us for a portable copy of your data.

Not Be Subject to Automated Decision-Making: Avoid decisions solely based on automated processes. We do not engage in such processes.

Withdraw Consent: Withdraw consent for data processing where applicable. Update preferences in Account Privacy or contact us.

Lodge a Complaint: File a complaint with your local data protection authority. Contact the UK Information Commissioner's Office (ICO) or your local authority.

For tailored advertising, see Section 5 for more details.

We collect various types of personal data categorized as follows:

3.1 Data Collected During Account Creation

• User Data: Includes your name, email, password, date of birth, gender, and country.
• Street Address: Used for eligibility verification, billing, and physical deliveries.

3.2 Data Collected During Service Use

• Usage Data: Includes streaming history, playlists, interactions, and device information (e.g., IP address, browser type).
• Technical Data: Covers URL data, device identifiers, and network performance.
• Location Data: Non-precise location data derived from IP address.
• Sensor Data: Includes motion and orientation data if required for specific features.

3.3 Additional Data You Provide

• Voice Data: Collected for voice-controlled features (where applicable).
• Payment Data: Includes payment method details, billing information, and transaction history.
• Survey Data: Information provided during research or feedback activities.

Sinai processes your data for purposes such as:

To provide the Sinai Service (Legal Basis: Performance of a Contract) - Using User Data, Usage Data, Payment Data.

To improve service functionality (Legal Basis: Legitimate Interest) - Using Usage Data, Technical Data.

For marketing or tailored advertising (Legal Basis: Consent or Legitimate Interest) - Using User Data, Usage Data, Survey Data.

To comply with legal obligations (Legal Basis: Compliance with Legal Obligations) - Using User Data, Payment Data, Location Data.

To prevent fraud and maintain security (Legal Basis: Legitimate Interest) - Using Technical Data, Usage Data, Payment Data.

To comply with requests from law enforcement (Legal Basis: Compliance with Legal Obligations) - Using User Data, Usage Data.

We share data only as necessary with:

• Service Providers: For customer support, technical infrastructure, and marketing.
• Payment Partners: To process transactions and prevent fraud.
• Advertising Partners: For tailored advertising and performance measurement.
• Legal Authorities: To comply with valid legal processes.
• Group Companies: For internal operations and feature development.
• Acquirers: If Sinai undergoes a merger or sale.

We retain personal data:

• For as long as you maintain your account.
• For limited periods to comply with legal obligations (e.g., tax records, fraud prevention).
• For a maximum of 90 days for temporary data (e.g., search history).

Your data may be transferred to countries with different privacy laws. Sinai ensures compliance by:

• Using Standard Contractual Clauses (SCCs) for data transfers.
• Leveraging countries with Adequacy Decisions by the European Commission.

Sinai employs measures such as encryption, pseudonymization, and access controls to protect personal data. You can enhance security by using strong passwords and logging out of shared devices.

The Sinai Service is not available to children under 13 or the applicable minimum age in your region. For younger users, we recommend Sinai Kids accounts where available.

We may update this Policy from time to time. For material changes, we will provide prominent notice (e.g., through the Sinai Service or email).

For questions about this Policy, contact our Data Protection Officer:

• Email: privacy@sinaigospel.com
• Mail: Sinai Global Ltd, 124 City Road, EC1V 2NX, London, England

Sinai Ltd is the data controller for personal data processed under this Policy.