Privacy Policy

1. INTRODUCTION
Mindcraft Inc. (“Disbate,” “we,” “our,” or “us”) operates a free, user-generated video-debate mobile application (the “Service”). This Privacy Policy sets forth the manner in which we collect, process, store, share, and protect Personal Data obtained through the Service. By downloading, installing, or using the Service, you acknowledge that you have read and understood this Privacy Policy and agree to be bound by its terms and by our Terms of Use. If you do not agree, you must refrain from accessing or using the Service.

2. DEFINITIONS
For ease of reference, the following terms have the meanings indicated. “Personal Data” means any information that identifies or can reasonably be linked to an identifiable natural person. “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, and deletion. “User-Generated Content” (“UGC”) means any video, audio, image, text, or metadata voluntarily submitted by a user through the Service. “Service Provider” means a third party that processes data on our behalf under written confidentiality obligations. Other capitalised terms have the meanings given in the Terms of Use.

3. SCOPE OF THIS POLICY
This Privacy Policy governs data collected exclusively through the Disbate mobile application and any in-app communications. It does not cover information gathered by unaffiliated websites, offline means, or services that we do not control. Where our Service contains links to external sites or embeds third-party content, you understand that their privacy practices are governed by their own policies and that Disbate is not responsible for their acts or omissions.

4. DATA WE COLLECT
We purposefully collect only minimal data required to operate a safe, functional video-hosting platform. When you create an account, we record your email address, chosen display name, encrypted password, preferred language, and self-declared age bracket. When you upload or record UGC, we process the media file, any accompanying title or caption, and the timestamp of submission. Should you contact support, we collect the content of your enquiry and any screenshots or attachments you choose to transmit. We do not automatically collect geolocation coordinates, advertising identifiers, IP addresses, or behavioural click-stream analytics.

5. OPTIONAL INFORMATION
Certain features, such as newsletter enrollment, phone-based account recovery, or voluntary surveys, may invite additional information (for example, a telephone number or user feedback). Supplying such data is entirely at your discretion and is not a prerequisite to the core debate functionality. Declining to provide optional information will not limit your ability to view, upload, or judge debates.

6. LEGAL BASIS FOR PROCESSING
For users located in jurisdictions requiring a lawful ground for Processing—most notably the European Economic Area—Disbate relies on four alternative bases: (i) contractual necessity, insofar as Processing is required to provide the Service you request; (ii) our legitimate interests in maintaining, securing, and improving a public debate platform, provided those interests are not overridden by your fundamental rights; (iii) compliance with legal obligations, including record-keeping and law-enforcement requests; and (iv) your consent, which we seek for non-essential communications and may withdraw at any time.

7. HOW WE USE INFORMATION
We use Personal Data to authenticate and manage accounts, encode and stream videos, display comments and voting metrics, respond to support requests, and enforce the Community Rules. We analyse aggregated, non-identifiable statistics to understand submission volumes, storage requirements, and server performance. We do not profile users for advertising, track browsing behaviour across services, or sell Personal Data to third parties.

8. USER-GENERATED CONTENT LICENSE
By uploading UGC you grant Disbate a worldwide, perpetual, royalty-free, sublicensable licence to store, reproduce, adapt, distribute, publicly display, and otherwise exploit the content solely in connection with operating, promoting, or preserving the Service. You represent that you own or otherwise control all necessary rights in your UGC and that its publication on the Service will not violate any law or third-party right.

9. EMAIL COMMUNICATIONS
We use your email address (and no other messaging channel) to (i) verify your account, (ii) send mandatory service or policy notices, (iii) respond to enquiries, and (iv) deliver optional newsletters to which you have expressly subscribed. You may unsubscribe from non-essential messages at any time by following the instructions contained in each email. We do not send unsolicited commercial emails and we never share email lists with advertisers.

10. THIRD-PARTY SOURCES
You may, at your option, integrate Disbate with a social-sign-in or share videos to an external platform; in such cases we receive only the data elements you expressly permit that third party to disclose (e.g., verified email address). We do not pull public profile information or friend lists without your authorisation.

11. DATA SHARING
We share Personal Data only with: (a) Service Providers who supply secure cloud hosting, video transcoding, or moderation tools; (b) successor entities in a corporate reorganisation, provided equivalent privacy safeguards are maintained; and (c) competent authorities when disclosure is legally mandated or necessary to protect individuals from harm. We contractually prohibit Service Providers from using Personal Data for any purpose outside our instructions.

12. VIDEO HOSTING AND PUBLIC DISPLAY
Debate videos are intended to be publicly accessible to all users of the Service. When you publish a debate, you acknowledge and accept that the video, along with your display name and the date of posting, will be viewable by others and may be quoted or critiqued within the platform. Private or unlisted sharing modes are not presently offered; please refrain from uploading content you prefer to keep confidential.

13. MODERATION AND AUTOMATED TOOLS
To maintain community standards, Disbate employs both human moderators and automated filtering technologies. Automated tools may flag potential violations such as nudity, violent imagery, or hate symbols; human reviewers make final determinations. Moderation decisions are logged and retained for accountability. Users may appeal removals by contacting feedback@disbate.com.

14. DATA RETENTION
Personal Data tied to an active account remains until you delete it or request erasure. Upon account deletion, we queue all associated UGC and profile data for eradication within thirty (30) days, subject to (i) legal retention requirements and (ii) our need to resolve outstanding disputes or enforce Terms of Use violations. Back-up copies are automatically overwritten thirty (30) days later.

15. INTERNATIONAL TRANSFERS
Disbate is headquartered in the United States. If you access the Service from outside the U.S., you acknowledge that your data will be transferred to, stored in, and processed on servers located in jurisdictions that may not provide equivalent data-protection laws. Where required, we rely on Standard Contractual Clauses or similar legal mechanisms to legitimise cross-border transfers.

16. DATA SECURITY
We deploy administrative, technical, and physical measures designed to protect Personal Data against unauthorised access, destruction, or alteration. Such measures include TLS encryption, hashed passwords, least-privilege access controls, penetration testing, and incident-response protocols. No security system is infallible; you are responsible for safeguarding your login credentials and promptly notifying us of any suspected compromise.

17. COOKIES AND TRACKING TECHNOLOGIES
The Disbate mobile application does not employ cookies, web beacons, or device fingerprinting. If future web-based features introduce cookies for strictly necessary functions (e.g., maintaining session state), we will update this Policy and obtain any legally required consent before activation.

18. CHILDREN’S PRIVACY
The Service is intended for users aged thirteen (13) years or older. We do not knowingly collect Personal Data from children under 13. If we discover that a child has provided data, we will delete the account and purge all associated content. Parents who believe their child has submitted data may contact us at feedback@disbate.com.

19. YOUR PRIVACY RIGHTS
Subject to verification of identity, you may exercise the following rights: access, rectification, erasure, restriction, objection, and data portability. To initiate a request, email feedback@disbate.com and specify the right you wish to invoke. We will respond within thirty (30) days, or such shorter period as mandated by applicable law.

20. CALIFORNIA PRIVACY DISCLOSURE
Disbate does not sell Personal Data as defined by the California Consumer Privacy Act (“CCPA”). California residents may request (a) disclosure of categories of Personal Data collected, (b) deletion of Personal Data, and (c) information about disclosures made for a business purpose in the preceding twelve (12) months. Requests may be submitted to feedback@disbate.com; Disbate will not discriminate against you for exercising CCPA rights.

21. GDPR COMPLIANCE
Where the General Data Protection Regulation (“GDPR”) applies, EU/EEA users have additional rights, including the right to lodge a complaint with a supervisory authority. Disbate has appointed feedback@disbate.com as its contact point for EU privacy matters. We store EU Personal Data in fully vetted, DPA-compliant cloud services and apply GDPR standards globally.

22. PERSONNEL DATA
If you are an employee, contractor, or applicant, we collect only data necessary for human-resources administration and statutory compliance. Such data is retained in accordance with employment laws and internal retention policies and is never used for advertising or sold to third parties.

23. BUSINESS TRANSFERS AND AFFILIATES
In the event of a merger, acquisition, reorganisation, or sale of substantially all assets, Personal Data may be transferred to the acquiring entity, provided that entity agrees to honour this Privacy Policy. We may also share data with wholly owned subsidiaries (“Corporate Affiliates”) under common control, subject to equivalent protective measures.

24. ADVERTISING AND PROMOTIONS
The current version of the Service is advertisement-free. Should Disbate introduce sponsored content or promotions in the future, we will not share Personal Data with advertisers and will update this Policy to describe any new data practices.

25. GOVERNING LAW AND DISPUTE RESOLUTION
This Privacy Policy is governed by the laws of the State of Delaware, United States, without regard to conflict-of-law rules. Any disputes arising under or in connection with this Policy shall be resolved in accordance with the dispute-resolution provisions contained in the Terms of Use.

26. CHANGES TO THIS POLICY
We may revise this Privacy Policy from time to time. Material changes will be communicated via in-app notice or email at least fourteen (14) days before the effective date. Your continued use of the Service after that date constitutes acceptance of the amended Policy.

27. CONTACT INFORMATION
If you have questions, concerns, or requests regarding privacy, please contact:

Mindcraft Inc.
3 Germay Dr,  Wilmington, DE 19804 USA
Email: feedback@disbate.com

If you believe we have not addressed your privacy concern satisfactorily, you may have the right to lodge a complaint with your local data-protection authority.