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This privacy policy (“Privacy Policy” or “Policy”) describes how Seven Technologies S.L. including any of its affiliates (“Se7en”, “we”, “us”, or “our”) collect, use and disclose certain information, including your personal information and the choices you can make about that information.
We are a software development and service provider company that provides various services and develop products in the adtech industry. Among others, we operate software platforms (“Platform”) that connect media buyers (“Advertisers”) with sellers of advertising inventory ("Publishers” and “Services” as applicable)
This Privacy Policy governs our processing practices when you (i) merely visit and browse our website https://www.videoheroes.tv/ ("website"), (ii) either a publisher, advertiser or other ad-network use our Services or (iii) when you are an end user interacting with our Publisher’s assets and we process your personal information.
For the purpose of this Privacy Policy a visitor, publisher, advertiser and ad network collectively shall be referred to as “you” unless the distinction is required.
This Privacy Policy further includes or incorporates specific information required under applicable data protection laws for residents of certain jurisdictions, among others:
If you are a located in the EEA or UK – this Privacy Policy further details our lawful basis for processing Personal Data, information regarding cross border data transfer and your rights, as well as additional information we are required to disclose to you under the EU and the UK General Data Protection Regulations (collectively “GDPR”).
If you are a California resident - please also review our CCPA Privacy Notice which serves as a Notice at Collection and Privacy Policy as required under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA”) and further details the categories of information collected and additional information regarding our privacy practices, including your rights under the CCPA and other California privacy laws.
Additional Information to certain United States Residents - please also review “Additional Notice for US Residents” section of this Privacy Policy to learn more about our privacy practices and your rights under these territories.
Se7en participates in the IAB Transparency & Consent Framework and complies with its Specifications and policies. Se7en’s vendor number within the framework is 1083.
1. 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.
2. CONTACT INFORMATION AND DATA CONTROLLER INFORMATION:
Seven Technologies S.L. incorporated under the laws of Spain, and it is the controller of your Personal Data.
You may contact us and our DPO at: privacy@videoheroes.tv or support@videoheroes.tv.
3. 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“). Non-Personal Data collected may includes technical information regarding your device or browser, type of operating system, scope, frequency, interactions with the website, and other technical information regarding the device used – all is considered as Non-Personal Data when collected on an aggregate basis, or otherwise not combined with any identifiers. We may further process and anonymize Personal Data in a manner that the data will be Non-Personal Data. Non-Personal Data may be used by us without limitation and for any purpose. Some of this information may be considered “de-identified” under applicable laws and when we rely on data that has been “de-identified”, we will take reasonable measures to ensure that the de-identified information cannot be associated with an individual, household, or device and not attempt to re-identify it.
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:
Online Identifiers and Usage Data:
When you access our website, we collect certain online identifiers such as: IP address, cookie ID, agent ID, unique identifiers (“Online Identifiers”).
We further collect data related to your interaction with our website which includes your click stream data, which sites your visited, which pages you viewed on our website, etc. (“Usage Data”). The Usage Data is usually connected to an Online Identifier.
Maintaining the Website:
First party cookies are strictly necessary and are used to enable the operation of the website.
First party cookies are strictly necessary and processing of Online Identifiers 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.
Respond to a Query:
We will use your email in order 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.
Account:
When the publisher uses our Service, they will create an account or be designated with an account, from which you may use the Service and review the reports. The account information includes you Contact Information, billing information, access logs and usage data (such as the time and date the account was accessed the duration).
Account information is processed solely to provide the Services.
Processed for the purpose of fulfilling our contract obligations with. Usage data is used to fix errors and for our legitimate interest in improving our services.
Email Address, Invoices: we will send publishers’ invoices, materials and marketing content through the email information you provided during your onboarding.
Direct Marketing:
We will use this information to keep you updated with offers and content such as updates, new capabilities and features, and to send you invoices and supporting documentation.
We process such information subject to our legitimate interest. You can opt-out at any time, however certain content (such as invoices) will still be sent.
Information Provided Through Support: If you contact us for support, we will process your Contact Information and any other information you provide us with
Support:
We process the information solely to provide you with the technical support needed.
Processed for the purpose of fulfilling our contract obligations with.
End User Consent & Privacy Preference
When you visit a website and are given the option to consent to the use of profiles for personalized advertising, your decision is saved and shared with advertising providers. This ensures that the advertisements you see align with your chosen preference.
The collection and processing of your consent and privacy preferences enable us to (i) verify information about the transparency, consent, or objection to certain advertiser, processing activity etc. (ii) Retrieve or pass on consent strings. (iii) Respect signals communicated by a CMP or received from a third party who forwarded the signal originating from a CMP.
We process such information subject to our legitimate interest as such processing is necessary in order to enable our service and to allow third party entities to respect your privacy preferences.
End User Data:
End users, are individuals browsing publishers’ assets and views advertisers’ ads (“End User”), we process certain information on End Users (“End User Data”): identifiers, unique identifier that may also be generated and created by third parties, IP address, Privacy or Preference String, TCF sting, the URL the End User is browsing, the interaction with the ads or the publisher assets (viewed, clicked, etc.), country level location extracted from the IP, type of browser, language, type of device and other technical data.
Deliver and display contextual content and advertising, reporting and measurements:
We use the End User Data to place contextual content, which is not advertisement.
We share the End User Data with the advertisers so that they are able to display relevant advertisement to you.
We use the aggregated End User Data to provide our publishers with insights and reports regarding their campaigns, meaning aggregated measurements and reporting.
We process the End User Data upon consent provided through the consent string, TCF string.
Otherwise, the aggregated data is used in our legitimate interest in providing the Service, and conducting research for improving the Service, all as detailed in the Legitimate Interest Claim below.
In certain aspects of our Service, we act as the “data processor” or “service provider”, in which we will rely on our publishers to obtain the necessary lawful basis for processing the end user personal data.
We use third-party advertising companies to serve ads when you visit our Publishers assets. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp
We place First Party Session Cookies on publishers’ website or app where our player is placed. These cookies collect certain end user data, these session cookies do not create profiles or preference, merely tells us how the end user engages with the ads and webpage. In certain cases, and subject to End User consent (where applicable), based on first party session cookies and data we, using third party solutions and technologies, generate and assign End Users with a unique ID ("Unified ID"). The Unified ID will enable us to customize the Service, advertisement and content as well as enhance your experience.
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.
4. OUR LEGITIMATE INTEREST CLAIM (DISCLOSURE AS REQUIRED BY TCF 2.2):
In addition to the information provided in the section above, we want to take a moment to explain the legitimate interest at stake when we process End User Data, as it directly impacts the services we provide to our publishers and advertisers. In most cases when we, or our publisher, deliver interest based, cross contextual advertisements that cater to your interests and preferences, we will base the processing of Personal Data on consent, as detailed in the table above, and transfer your preference to our publishers and advertisers. However, when we use certain data, which includes Personal Data such as Online Identifiers, for collecting and processing your consent and privacy preferences, improving the services, or technically delivering the ads, we do so based on our legitimate interest is essential to the sustainability of our platform and services and allowing us to demonstrate compliance with the accountability principle pursuant to GDPR Art. 5(2) and 24. This processing should be expected by End Users. We understand that privacy is of utmost importance, and we are committed to protecting your rights. We adhere to applicable privacy standards and regulations, provide transparent information about our data processing practices, and you have the ability to control your preferences and opt out. We want to assure you that we conduct a careful balancing test to ensure that our legitimate interest does not unduly infringe upon your rights and freedoms.
5. 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, when you visit our website or interact with our Platform, including through the use of Cookies (as detailed below) and similar tracking technologies.
· 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, such as our publishers, applicable cookie management platforms and etc.
6. COOKIES AND SIMILAR TECHNOLOGIES:
We use “cookies” (or similar tracking technologies) when you access our website. The use of cookies is a standard industry-wide practice. A “cookie” is a small piece of information that a website assigns and stores on your computer while you are viewing a website. Cookies can be used for various purposes, including allowing you to navigate between pages efficiently, as well as for statistical purposes, analytic purposes and marketing.
7. DATA SHARING – CATEGORIES OF RECIPIENTS WE SHARE PERSONAL DATA WITH:
We share your data with third parties, including our advertisers and publishers or service providers that help us provide our Services. You can find here information about the categories of such third-party recipients.
Advertisers
End User Data
End User Consent and Privacy Preferences
Enabling the advertisers to display ads or content that best suit such web-page, as a part of our Services.
Publishers
As part of our Services, we provide our publishers with reports that includes measurements data of ads and other information on how effective the campaign is, the applicable revenues, the number of views or clicks the ad generated and where, etc.
Third Party Fraud detection providers
These service providers ensure the End Users’ are actual individuals and not fraudulent traffic.
All data
All data
Any acquirer of our business
Governmental agencies or authorized third parties.
Service Providers
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, recruitment providers, CRM systems, Salesforce, etc., 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.
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.
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, publishers and advertisers, 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).
8. 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.
9. SECURITY MEASURES:
We work hard to protect the Personal Data we process from unauthorized access, alteration, disclosure, or destruction. We have implemented physical, technical, and administrative security measures for the Services that comply with applicable laws and industry, such as encryption using SSL, we minimize the amount of data that we store on our servers, restricting access to Personal Data to Se7en’s employees, contractors, and agents, etc. Note that we cannot be held responsible for unauthorized or unintended access beyond our control, and we make no warranty, express, implied, or otherwise, that we will always be able to prevent such access.
Please contact us at: privacy@videoheroes.tv if you feel that your privacy was not dealt with properly, 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. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.
10. INTERNATIONAL DATA TRANSFER:
Our data servers in which we host and store the information are located in the [location of servers]. In the event that we need to transfer your Personal Data 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. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments or assurances from the data importer to protect your Personal Information, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the European Commission. Some of these assurances are well-recognized certification schemes.
11. YOUR RIGHTS
We acknowledge that different people have different privacy concerns and preferences. Our goal is to be clear about what information we collect so that you can make meaningful choices about how it is used. We allow you to exercise certain choices, rights, and controls in connection with your information. Depending on your relationship with us, your jurisdiction and the data protection laws that apply to you, you have the right to control and request certain limitations or rights to be executed.
The principal rights that may apply to your Personal Data (subject to your jurisdiction and additional conditions) may include:
Right to be informed, right to know, and right to a list of specific third parties
You have the right to be provided with information regarding our Personal Data collection and privacy practices. You also have the right, at our option, to receive a list of the specific third parties to which we have disclosed either your Personal Data or any Personal Data.
This Privacy Policy also details our Personal Data handling practices.
Access rights, right to inspect your Personal Data
You have the right to confirm whether we collect Personal Data about you and to know which Personal Data we specifically hold about you, as well as receive a copy of such or access it. If you wish to receive a copy of the Personal Data, please submit the Data Subject Request available here and send it to our DPO: privacy@videoheroes.tv
Right to correction/rectification
You have the right to correct inaccuracies in your Personal Data in the event you found it incorrect, outdated, etc. (or otherwise request its deletion), taking into account the nature and purposes of each processing activity. If you wish to exercise this right, please submit the Data Subject Request available here and send it to our DPO: privacy@videoheroes.tv
Right to be forgotten, right to deletion
You have the right to request the deletion of certain Personal Data we process, if specific conditions are satisfied, for example, if you think we no longer need to use it for the purpose we collected it; in the event that the collection was based on your consent; where we have used it unlawfully, or; where we are subject to a legal obligation to delete your Personal Data. Deletion request will be subject to our rights and obligations under applicable law (for example, our legitimate interests to maintain record keeping, completing transactions, providing a service that you have requested, taking actions reasonably anticipated within the context of our ongoing business relationship with you, detecting security incidents, protecting against illegal activity; debugging; exercising right provided for by law, etc.).
If you wish to exercise this right, please submit the available here and send it to our DPO: privacy@videoheroes.tv
You are not required to create an account with us to submit a deletion request.
Right to portability
You have the right to obtain the Personal Data in a portable, and to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance. We will select the format in which we provide your copy.
If you wish to exercise this right, please submit the Data Subject Request form available here and send it to our DPO: privacy@videoheroes.tv
Right to withdraw consent. Right to opt out from: (i) “sale” or “share” of Personal Data (as defined under US laws); (ii) Targeted advertising; and (iii) Profiling and automated decision making
Where we process Personal Data based on your consent, you have the right to withdraw such consent at any time.
For example - you have the right to withdraw consent from receiving any marketing communication from us or otherwise opt-out, by unsubscribing through the message received. You have the right to opt-out or otherwise withdraw consent from processing of Personal Data through our use of cookies, by changing your preferences through the cookie setting tool available on our website.
If and to the extent applicable, you have the right to opt out of the “sale” or “share” of your Personal Data, which includes opting-out of our practice of using cookies for the purposes of targeted advertising, analytic, etc., by clicking on the “Do Not Sell or Share My Personal Information” link on our website or communicating your opt out through opt-out preference signals, like Global Privacy Control (learn more here).
In any event, please keep in mind that opt-out tools are limited to the browser or device you use because they work off your browser ID and device ID and, accordingly, you will need to opt-out on each browser and device you use. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again.
We do not profile you in a manner that has a significant effect on you or other individuals, therefore we do not provide an opt-out option from such use of Personal Data.
Right to Object
You have the right to object to any use of your Personal Data which we have justified by our legitimate interest if you believe your fundamental rights and freedoms to data protection outweigh our legitimate interest.
If you wish to exercise this right, please submit the Data Subject Request form available here and send it to our DPO: privacy@videoheroes.tv
Right to Restrict Processing
You have the right to ask us to restrict or limit the purpose for which we process your Personal Data, where certain conditions are satisfied (for example, where you contest the accuracy of the Personal Data, for a period enabling us to verify its accuracy).
If you wish to exercise this right, please submit the Data Subject Request form available here and send it to our DPO: privacy@videoheroes.tv
Right to appeal or lodge a complaint
If we decline to take action on your request, we will inform you without undue delay as required under applicable laws. The notification will include a justification for declining to take action and instructions on how you may appeal, if applicable. Within the timeframe set under applicable law as of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to your appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority.
Where the GDPR applies, you have the right to lodge a complaint with the applicable Data Protection Authority in the EU or the Information Commissioner in the UK.
You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request (“DSR”) form available here.
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.
12. IBA OPT OUT OPTIONS
Interest-Based Advertising ("IBA"): We do not sell your Personal Data. 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
· Google https://adssettings.google.com/authenticated
· Google Analytics https://tools.google.com/dlpage/gaoptout
· Global privacy control preference https://globalprivacycontrol.org/
Further, on every webpage or app you browse there are “cookie settings” through which you may opt out. Additional information on opt-out rights and means are available through our DSR form.
13. 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: privacy@videoheroes.tv if you have reason to believe that a child has shared any information with us.
14. ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS
This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”) effective November 2020, and as amended by the CPRA, effective January 1, 2023.
Please see the CCPA Privacy Notice which discloses the categories of personal information collected, purpose of processing, source, categories of recipients with whom the personal information is shared for a business purpose, whether the personal information is sole or shared, the retention period, and how to exercise your rights as a California resident.
15. JURISDICTION-SPECIFIC NOTICES
Information provided below supplements the information contained in this Privacy Policy and applies to residents of such states. These additional disclosures are intended to provide you with additional information with regard to our handling of your Personal Data and certain consumer rights.
i. Additional Notice to California Residents:
This section applies only to California residents. Pursuant to the CCPA.
Please see the CCPA Privacy Notice which discloses the categories of “personal information” collected, purpose of processing, source, categories of recipients with whom the “personal information” is shared for a “business purpose”, whether the personal information is “sold” or “shared”, the retention period, and how to exercise your rights as a California resident.
ii. 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. However, subject to the definition of the term “sale” under applicable US privacy laws, our practice of using “cookies or other third-party advertising services and sharing Personal Data for such purpose to third party advertising and marketing providers (e.g., providers of marketing tools and analytic tools, advertising networks, social media networks, media buying, search platforms) is considered a “sale”.
Such practice includes the following Personal Data categories shared with these third parties:
Identifiers – online identifiers such as IP and Cookie ID;
Internet and electronic network activity information – such as your engagement with our website and ads.
Geolocation data – derived from IP.
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:
Access – the right to confirm whether we are processing their Personal Data and to obtain a copy of their Personal Data in a portable and, to the extent technically feasible, readily usable format.
List of Third Parties – the right to receive a list of the specific third parties to which we have disclosed either your Personal Data or any Personal Data.
Delete – the right to request us to delete their Personal Data provided to or obtained by us.
Correct – the right to request us to correct inaccuracies in their Personal Data, taking into account the nature and purposes of the processing of the Personal Data.
Opt-Out – the right to opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Data; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Data for profiling in furtherance of making decisions that produce legal or similarly significant effects. However, as noted above, we do not engage in profiling in furtherance of legal or similarly significant decisions.
Appeal – the right to appeal if we decline to take action in response to your exercise of a privacy right.
Non-Discrimination – the right to not be discriminated against for exercising your privacy rights.
Exercising Consumer Privacy Rights:
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws by submitting a Data Subject Request form available here or sending an email to our DPO: privacy@videoheroes.tv
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.
Authorized agents may initiate a request on behalf of another individual, provided that they provide proof of their authorization, and we may also require that the individual directly verify his/her identity and the authority of the authorized agent.
We will respond to your request within the timeframe required under applicable law, and we reserve the right to extend the response time subject to applicable law requirements. If we refuse to take action on a request, we will notify you and our notification will include a justification for declining to take action and instructions on how you may appeal. Within the timeframe set out under applicable law of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may submit a complaint to the applicable authority or Attorney General of your jurisdiction.
Sale of Personal Data: We do not sell Personal Data. We may “share” Personal Information for “interest-based advertising” or “cross-context behavioral advertising” as further detailed in our CCPA Privacy Notice.
Consumer Rights:
Residents of certain U.S. states, including Colorado, Connecticut, Florida, Montana, Nevada, Oregon Texas, Virginia, and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:
● Access. The right to confirm whether we are processing their Personal Information and to obtain a copy of their Personal Information in a portable and, to the extent technically feasible, readily usable format.
● Delete. The right to delete their Personal Information provided to or obtained by us.
● Correct. The right to correct inaccuracies in their Personal Information, taking into account the nature and purposes of the processing of the personal information.
● Opt-Out. To opt out of certain types of processing, including: (i) to opt out of the “sale” of their Personal Information; (ii) to opt out of targeted advertising by us; and (iii) to opt out of any processing of Personal Information for purposes of making decisions that produce legal or similarly significant effects.
You may submit a request to exercise most of your privacy rights under U.S. state privacy laws online using our DSR Form. When you submit a request, 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 in order 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.
Authorized agents may initiate a request on behalf of another individual by contacting us at privacy@videoheroes.tv; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.