SHORTICAL PRIVACY POLICY

[Last Modified: July 27, 2025]

 

This Privacy Policy (“Privacy Policy”), is an integral part of our End User License Agreement (“EULA”), and governs the processing and transfer of personal data collected or processed by Short Entertainment Ltd. (“Company”, “we”, “us” or “our”) when you accessing or using our mobile application or our services, all as detailed in the applicable EULA (respectively the “App” and “Service”).

Any capitalized terms not defined herein shall have the meaning ascribed to them in the EULA.

This Privacy Policy explains what data we may collect from you, how such data may be used or shared with others, how we safeguard it and how you may exercise your rights related to your Personal Data (as defined below), among others, and where applicable, as required according to the EU General Data Protection Regulation (“GDPR”),the Brazilian General Data Protection Law (as amended by Law No. 13,853/2019) ("LGPD"),  the California Consumer Privacy Act (“CCPA”) and other US states.

If you have any questions regarding this Privacy Policy or our data practices, you are welcome to contact us at: support@shortical.com

This Privacy Policy explains our data collection practices that are applicable to any users of our App or our Services (“you” or “your”).POLICY AMENDMENTS:

We reserve the right to amend this Policy from time to time, at our sole discretion. The most recent version of the Policy will always be posted on the website. The updated date of the Policy will be reflected in the “Last Modified” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective within 30-days upon the display of the modified Policy. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.

 

CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:

Short Entertainment LTD incorporated under the laws of Israel, and it is the controller of your Personal Data.

You may contact us and our DPO: support@shortical.com

 

DATA SETS WE COLLECT AND FOR WHAT PURPOSE:

You can find here information regarding the purposes for which we process your personal data as well as our lawful basis for processing, the definition of “personal” and “non-personal” data, and how it is technically processed.

 

Non-Personal Data

During your interaction with our website and Services, we may collect aggregated, non-personal non-identifiable information, which may be made available or gathered via your access to and use of the Services (“Non-Personal Data “). We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data being collected may include your aggregated usage information and technical information transmitted by your device, such as: the type of browser or device you use, language preference, time and date stamp, country location, etc.

 

Personal Data

We may also collect from you, directly or indirectly, during your access or interaction with the website or Services, individually identifiable information, namely information that identifies an individual or may, with reasonable effort, be used to identify an individual (“Personal Data”). The types of Personal Data that we collect as well as the purpose for processing and the lawfulness are specified in the table below.

We do not knowingly collect or process any Personal Data constituting or revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning a person's health or data concerning a person’s sex life or sexual orientation (“Special Categories of Personal Data”).

 

The table below details the processing of Personal Data, the purpose, lawful basis, and processing operations:

DATA SET

PURPOSE AND OPERATIONS

LAWFUL BASIS

Registration Information:

In order to use the App you are required to register and create an account by login using your Apple, Facebook or Google account or otherwise by entering your email address.

If you login through Apple, Facebook, or Google, we will receive information connected to such account. we will collect the Personal Data that you are required to provide us during the registry process, such as your full name and email address.
Further, during the registration process you will be supplied with username and password for your account, at which time you thereby represent and warrant that you are responsible for maintaining the confidentiality of your details and password. You represent and warrant that you will not provide us with inaccurate, misleading or false information.

This information will be processed for the purpose of performing our contract with you, to set up your account with us and enable you to use our Services.
In addition, we may process your Personal Data for our legitimate interests, for example, to send you marketing and promotional messages and offers related to our Services. You are able to unsubscribe from receiving such correspondence from us by contacting us at: support@shortical.com
Please note that if you choose to unsubscribe from direct marketing, we may still retain your contact details and send you relevant service-related information such as invoices and subscription rates.

The registration information is processed to perform our contract with you and the direct marketing is subject to our legitimate interest.

Contact Information:

If you voluntarily contact us, you may be required to provide us with certain information such as your name, job title, company name, email address (“Contact Information”) and any additional information you decide to share with us.

We will use this data to respond to your inquiry.

We process such Contact Information subject to our legitimate interest.

We may keep such correspondence if we are legally required to.

In-App Payment Information:
When you make a payment through our App and offered Services, all payment are in-app payments and are subject to the applicable App Store terms and privacy policy.
Google Terms of Service
Google Privacy Policy
App Store Terms of Use
App Store Privacy Policy

We use in app payment processors; the registration and payment information are solely processed by the applicable app store provider. We do not store nor process any Personal Data when you process the payment.
We receive an order number which is connected to a user ID which was generated when installing the app (non identifiable).

The Payment Information is processed to perform our contract with you to provide you our Services..

Log Data and Unique Identifiers:
In case of an error in the App we collect data and information (through third-party service providers) such as “Log Data” or “Crash Data”. This data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the App when utilizing our Service, the time and date of your use of the Service, and other statistics.

In most cases, this data will not include Personal Data, however we treat this information as Personal Data as we may be able to reasonably identify you.

We process this data set for out legitimate Interest of protecting our App and Services and optimizing the App and Services.

Profiling Data:
When you using our App we may display advertisement, our partners, the advertisers may place an SDK (as detailed below) and collect certain data on you for the purpose of displaying advertisement.
If you wish to prevent the display of advertisements or other identifiers for interest-based advertising, you may change your device settings to reset such advertisement or opt-out of such advertising (typically, this is available under the “Privacy” or “Ads” section in your device settings).
Please note that if you reset your advertising settings or opt-out of interest based advertising, you may still see advertisements in our App, but those ads will not be targeted for you. Please note that such actions may result in a less enjoyable user experience.

Our partners will process this data to manage and deliver advertisements more effectively and personally, including contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners and advertisers, including for re-targeting purposes.

We process this information based on your consent as required under your jurisdiction provided through our cookie manager or similar technologies.

Usage Data:

We will collect information regarding your interaction with the App and Service, including your records on clicking, pages you viewed, click stream data, access time stamp, content you watched liked or saved to “My List”.

 

We use this data (i) to operate the App and Services  and enable its proper functionality (ii) For security and fraud prevention purposes (for example, to authorize you are a person) (iii) For debugging and to resolve technical problems. (iv) To understand how individuals use the App and Service (v) Personalize content and experiences on our Services, including providing you reports, recommendations and feedback based on your preferences; (vi) Optimize or improve our products, services and operations;

 

We process this information to perform our contract with you.

Installed App List:

We may collect information of the apps that are installed on your device.

We use this data (i) to operate the App and Services  and enable its proper functionality (ii) For security and fraud prevention purposes (iii) and for analytics purpose;

 

We process this information based on our legitimate interest.

Your mobile provider (i.e. Android, Apple and etc) may request you to actively consent for the collection of the installed application on your device, in such case the basis of processing your consent.

 

Please note that the actual processing operation per each purpose of use and lawful basis detailed in the table above may differ. Such processing operation usually includes a set of operations made by automated means, such as collection, storage, use, disclosure by transmission, erasure, or destruction. The transfer of personal data to third-party countries, as further detailed in the Data Transfer Section, is based on the same lawful basis as stipulated in the table above.

In addition, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts, and any other misuse of the Services and to enforce the Terms, as well as to protect the security or integrity of our databases and the Services, and to take precautions against legal liability. Such processing is based on our legitimate interests.

We may collect different categories of Personal Data and Non-Personal Data from you, depending on the nature of your interaction with the Services provided through the website and Platform, as detailed above. If we combine Personal Data with Non-Personal Data, the combined information will be treated as Personal Data or for as long as it remains combined.

 

HOW WE COLLECT YOUR INFORMATION:

Depending on the nature of your interaction with us, we may collect the above detailed information from you, as follows:

• Automatically, We process this information based on your consent provided through the organic in-app permissions in order to execute our contract with you and provide you with our services.

• When you voluntarily choose to provide us with information, such as when you contact us, all as detailed in this Policy.

• Provided from third-parties.

 

SDK & TRACKING TECHNOLOGIES:

Our Services and some of our Service Providers utilize “cookies” or “software development kits (“SDK”)” anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps and Services as a whole.

The specific SDK we currently use, the purpose of the SDK, their privacy policy and opt-out controls are set forth in the table below:

NAME

PURPOSE

PRIVACY AND OPT OUT

Google Play

Apple

In-app billing

Google Play Privacy Policy: https://play.google.com/about/privacy-security-deception
https://policies.google.com/privacy?hl=en

Apple privacy policy:

https://www.apple.com/legal/privacy/en-ww/

Firebase

Jetpack

Mixpanel

• Remote Config- data
• storage and processing location
• Crashlytics- data
• Cloud Messaging
• data encryption
• security purpose
• a/b testing
• in-app messaging
• predictions
• analytics

Firebase Privacy Policy: https://firebase.google.com/support/privacy

 

Mixpanel Privacy Policy: https://mixpanel.com/legal/privacy-policy/

 

Jetpack Privacy Policy:

https://jetpack.com/support/privacy/

• Advertisers:

• Applovin

• AppsFlyer

• RevenueCat
  Facebook Audience Network

And as may be updated from time to time (collectively “Advertisers”).

The Advertisers are advertising Service Providers. Their targeted advertising SDKs collect information about your browsing activity across multiple websites and online services in order to provide you with relevant advertisements on the App and Services of third parties. The information collected using these advertising SDK does not disclose your identity, and helps us analyze the effectiveness of our advertising.

• Applovin: https://www.applovin.com/privacy/
• Facebook Audience Network: https://www.facebook.com/about/privacy/
AppsFlyer: https://www.appsflyer.com/trust/privacy/

RevenueCat: https://www.revenuecat.com/privacy/

 

 

DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:

We share your data with third parties, including our partners or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.

CATEGORY OF RECIPIENT

DATA THAT WILL BE SHARED

PURPOSE OF SHARING

Advertisers

Online Identifiers

Display ads or content that best suit such application, as a part of our Services.

Service Providers

 

 

All data

We may disclose Personal Data to our service providers, contractors and third parties, including, but not limited to, our cloud and hosting provider, analytics and marketing providers, payment processors (in app payments), fraud prevention and analytic tools, tracking tools, the service providers are limited by contracts which limit their use of the data, and requires implementing security measures. The service providers process the data solely to provide the needed services. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.

Any acquirer of our business

All data

We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

Governmental agencies, or authorized third parties.

Subject to law enforcement authority request.

We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

 

When we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary for us to provide the Services. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only while ensuring compliance with all applicable data protection regulations (such service providers may use other non-personal data for their own benefit).

 

DATA RETENTION:

In general, we retain the Personal Data we collect for as long as it remains necessary for the purposes set forth above, all under the applicable regulation, or until you express your preference to optout, where applicable.

Other circumstances in which we will retain your Personal Information for longer periods of time include: (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data. Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we may delete it for any reason and at any time, without providing you with prior notice if our intention to do so.

 

SECURITY MEASURES:

We take great care in implementing physical, technical, and administrative security measures for the services that we believe comply with applicable regulation and industry standards to prevent your information from being accessed without the proper authorization, improperly used or disclosed, unlawfully destructed, or accidentally lost.

If you feel that your privacy was not dealt with properly or was dealt with in a way that was in breach of our Privacy Policy or if you become aware of a third party’s attempt to gain unauthorized access to any of your Personal Data, please contact us at our email. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) if we discover a security incident related to your Personal Data.

 

INTERNATIONAL DATA TRANSFER:

We use Google Cloud which are located in EU, US and Asia. Further, certain processing activities are conducted in Israel, or other countries. In the event of data transfer out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Further, when Personal Data collected within the EU is transferred outside the EU (and not to a recipient in a country that the European Commission has decided provides adequate protection) it shall be transferred under the provisions of the standard contractual clauses approved by the European Union. If you would like to understand more about these arrangements and your rights in connection therewith, please contact us at our email.

 

USER RIGHTS

According to data protection and privacy laws may grant you with certain rights with regards to your Personal Data, all according to your jurisdiction. The rights may include one or all of the following: (i) request to amend your Personal Data we store accessing; (ii) review and access your Personal Data that we hold; (iii) request to delete your Personal Data that we hold (as long as we do not have a legitimate reason for retaining the data); (iv) restrict or object to the process your Personal Data; (v) exercise your right of data portability (vi) contact to a supervisory authority in your jurisdiction and file a complaint; and (vii) withdraw consent (to the extent applicable). If you wish to submit a request to exercise your rights, please contact us at: support@shortical.com

When you contact us and request to exercise your rights regarding your Personal Data, we will require certain information from you in order to verify your identity and locate your data and that the process of locating and deleting the data may take reasonable time and effort, as required or permitted under applicable law. Data privacy and related laws in your jurisdiction may provide you with different or additional rights related to the data we collect from you, which may also apply.

You have the right to lodge a complaint with the EU Member State supervisory authority if you are not satisfied with the way in which we handled the complaint.

 

OPT OUT OPTIONS

Interest-Based Advertising ("IBA"): We do not sell your Personal Data. Some of our Apps may include providing you with advertisements therefor we may “share” your Personal Data with third parties for personalized advertising purposes. If you wish to opt-out from the sharing of your personal data with third parties for the purpose of cross-contextual interest-based advertising there are many way to do so, as further detailed below. Please note that even if you opt-out you may still see personalized ads based on information other companies and ad networks have collected about you, if you have not opted out of sharing with them.

For IBA opt out options on desktop and mobile websites, please visit:

• Digital Advertising Alliance (US) https://www.aboutads.info/choices/

• Digital Advertising Alliance (Canada) https://youradchoices.ca/en/tools

• Digital Advertising Alliance (EU) https://www.youronlinechoices.com/

• Network Advertising Initiative https://optout.networkadvertising.org/?c=1

 

ELIGIBILITY AND CHILDREN PRIVACY:

The Services are not intended for use by children (the phrase "child" shall mean an individual that is under the age defined by applicable law, which concerning the EEA is under the age of 16, and with respect to the US, under the age of 13), and we do not knowingly process children's information. We will discard any information we receive from a user that is considered a "child" immediately upon discovering that such a user shared information with us. Please contact us at: support@shortical.com if you have reason to believe that a child has shared any information with us.

 

ADDITIONAL NOTICE TO US RESIDENTS

Residents of certain U.S. states (depending on the applicable state law, acting as an individual or in the household context only and not in a commercial or employment context, as a job applicant or as a beneficiary of someone acting in an employment context or as representative of a business), may have additional rights under applicable privacy laws and be entitled to additional disclosures.

“Personal Data” under applicable US privacy laws, generally means any information that is linked or reasonably linkable to an identified or identifiable individual (and usually does not include publicly available information that is lawfully made available from government records, or that a consumer has otherwise made available to the public; de-identified or aggregated consumer information; or information excluded from the states laws scope.

“Sensitive Data” includes data revealing racial, ethnic or national origin; religious beliefs; information regarding an individual’s medical history, mental or physical health condition, diagnosis or medical treatment; neural data; status as transgender or non-binary; sex life or sexual orientation; status as a victim of a crime; citizenship or immigration status; genetic or biometric data; Personal Data collected from a known child; and precise geolocation data.

We are required to provide you with a clear and accessible privacy notice that includes the categories of Personal Data processed, including any Sensitive Data, the purpose of processing, the categories of Personal Data shared with third parties, the categories of third parties with whom Personal Data is shared, the categories of Personal Data that is sold or used for targeted advertising, if any, the categories of third parties to whom the Personal Data is sold, if any, a list of your data rights and instructions for exercising those rights and appealing decisions, and out contact information. This information is detailed under this Privacy Policy and further below.

Categories of Personal Data & Categories of Third Parties with Whom Personal Data is Shared:

Under the Privacy Policy, we describe our collection and processing of Personal Data, the categories of Personal Data that are collected or processed, and the purposes for which Personal Data is processed, stored or used. We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without obtaining your consent, unless we are otherwise entitled, required or permitted under applicable laws.

Additionally, this Privacy Policy, details and discloses the categories of third parties we share Personal Data with for a business purposes.

“Sale” of Personal Data:

Under US privacy laws, in principle, the term “sale” refers to disclosing or making available Personal Data to a third-party in exchange for monetary or other valuable consideration, including for targeted advertising purposes. We do not “sell” information as this term is commonly understood, meaning - we do not, and will not, disclose your Personal Data in direct exchange for money or some other form of payment. As detailed above we may share and disclose your Personal Data with Advertisers in order to provide you with ads and for targeted advertising purposes.

Consumer Rights Related to Their Personal Data:

Residents of certain U.S. states may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

• Right to Delete. You have the right to request us to delete the personal information we have collected about you.

• Right to Correct. You have the right to request us to correct inaccurate personal information we maintain about you.

• Right to Confirm Processing, Know and Access. You have the right to confirm whether we are processing your personal information and know and access the personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of personal information and service providers, contractors and third parties to whom we disclosed personal information, and the specific pieces of personal information we have collected about you. You have the right to receive this information in a format, to the extent technically feasible, that is portable, usable, and allows you to transmit the personal information to a person without impediment or hindrance.

• List of Specific Third Parties: You have the right, at our option, to receive a list of the specific third parties, other than natural persons, to which we have disclosed either: (1) your personal information or (2) any personal information.

• Rights Related to Profiling. You have the right to opt out of the processing of your personal information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer. However, this right does not apply because we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

• Rights Related to Sharing for Targeted and Cross-Context Behavioral Advertising or Sale. You have the right to opt out of the sharing of your personal information for targeted or cross-context behavioral advertising or the sale of your personal information.

• Rights Related to Sensitive Personal Information or Data. Data privacy laws may provide additional protection for sensitive personal information or data. However, this right does not apply because we do not process sensitive personal information or data.

• Right to No Discrimination. You have the right not to be discriminated against for exercising any of your privacy rights. This includes us not: (a) denying you goods or services; (b) charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; (c) providing you a different level or quality of goods or services; (d) suggesting to you that you will receive a different price or rate for goods or services or a different level or quality of goods or services; and (e) retaliating against you for exercising your privacy rights.

• Right to Appeal. If we decline to take action in response to your exercise of a privacy right, we will inform you of the reason for denying your request and provide you instructions on how to appeal the decision.

 

Exercising Consumer Privacy Rights:

You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by sending an email to: support@shortical.com

For certain rights, we will take steps to verify your identity and your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for denial and how to remedy any deficiencies, where applicable.

Appealing

You may appeal a denial of your privacy right requests by emailing us at support@shortical.com. Within 45 days of receipt of an appeal, we will inform you in writing of any action taken in response to the appeal, including a written explanation of the reasons for the decisions. If we deny your appeal, you may submit a complaint to the Attorney General of your state.

Authorized Agents

If permitted or required by applicable law, you may exercise your privacy rights through an authorized agent (which may include a guardian or conservator). If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us at support@shortical.com.

 

Shine the Light Law Disclosure for California Residents

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. If you are a California resident and would like to make such a request, please email us at: support@shortical.com