Truvid Privacy Policy
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LAST REVISED: OCTOBER 10, 2020
Welcome to Truvid, an online video platform (“Services”), provided to you by Truvid Inc. (“we”, “us” or “Truvid”). This Privacy Policy (“Privacy Policy”) to explain to you about our data collection and protection practices, when you access, use, interact or engage with any of the Services. Please be aware that this Privacy Policy is an integral part of our Terms and Conditions, available at: www.truvid.com/terms (the “Terms”), whether you are an end consumer who interacts with the Services or a business entity who engages with us and integrate the Services into your online assets, website or content. 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 California Consumer Privacy Act (“CCPA”) and the Brazilian General Protection Law ("LGPD"). In the event you are a California resident and the CCPA applies to you – please also review our CCPA Privacy Notice
THE HIGHLIGHTS
• You are not required by law to provide us with any Personal Data. Sharing Personal Data with us is entirely voluntary. However, some of the Company's operations may depend on providing us with certain Personal Data, as specified below.
• In general we use Personal Data (1) where we have a legitimate interest to do so (for example for website’s security purposes); (2) in order to perform a contract (for example, to provide you with the support you have requested or response to your inquiry); (3) where there is a legal obligation imposed on us or to protect our legal rights; and (4) otherwise with your consent to do so.
• You may be entitled under applicable law to request to review, amend, erase or restrict the processing of your Personal Data, all as detailed under this Policy.
• We do not sell, trade, or rent users’ Personal Data to third parties. We only share Personal Data for limited circumstances as specified herein.
APPLICABILITY
This Privacy Policy explains Truvid’s data collection practices that are applicable toward (i) our customers, which are our business partners, whether they are publishers, content editors, advertisers or any other type of business partners (“Partners”); (ii) our Partners’ end users; and (ii) the data practices relating to visitors of the Site (“Visitors”), Customers and Visitors will be jointly be referred to as “users” or “you”.
When we use the term Service, we may refer to one or more of the following platforms: (a) our website (i.e., when you access and visit our website we process certain data); (b) our multi-screen media player technology (“Media Player”) through which we may process certain data on our Partner’s end users; or (c) our ad server and respective BI and analytic services and dashboards (“Ad Server”) used by our Partners; or (d) our ad bidding and serving marketplace (“Market Place”).
INFORMATION COLLECTED
We may collect two types of data and information from you, depending on your interaction with us. The first type of information is non-identifiable and anonymous information (“Non-Personal Information” or “Non-Personal Data” as applicable). We are not aware of the identity of the individual from which we have collected the Non-Personal Information. Non-Personal Information which is being gathered consists of technical information, and may contain, among other things, the type of operating system and type of browser, type of device, Visitors’ action in the Site, or approximate geo-location.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information” or “Personal Data” as applicable). For avoidance of doubt, any Non-Personal Information connected or linked to any Personal Information shall be deemed as Personal Information as long as such connection or linkage exists.
You are not required by law to provide us with any information. You can always avoid from providing us certain Personal Information; however, you acknowledge that it may prevent you from engaging in certain Services or using certain features of the Site. We are considered as the Data Controller of the Personal Information we collect from our Visitors and Business Partners, however regarding the Personal Information we collect from our Partner’s end users we are considered a Data Processor (under the GDPR) or a service provider (under the CCPA).
Information we collect from Visitors of our Site
| Type of Personal Information | Purpose of Processing |
Contact Details In the event you contact us for support or other inquiries, either through the online form available on the site, by sending us an email or by other means of communications we make available, you will be requested to provide us your name, email address, and may provide us with your phone number. | We will use this information solely for the purpose of contacting you, responding to your inquiries and provide you with the support or information you have requested. This information is lawfully processed subject to contract necessity. |
Online Identifiers When you access our site, we may, either directly or indirectly collect your IP address. We may also collect technical Non-Personal Information, as detailed above. | We process this data subject to your consent provided through an applicable cookie notice. Note that, we do not attempt to analyze or determine your identity based on such information or otherwise combine it with any information such as your name or email address. The IP may be collected by our third-party analytic partners that offer ways to opt-out, all as detailed below. |
Recruitment In the event you are interested in joining our team, and wish to submit your CV, you will be required to provide us your name, email address, and CV. | Your provision of Personal Information in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal information concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information you have provided solely to communicate with you, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If you are hired, the information may be used in connection with employment and corporate management. |
Information we collect from our Business Partners
| Type of Personal Information | Purpose of Processing |
| If you are our Business Partner, we may collect Personal Information that you are required to submit to us when you engage with us, such as your or your personnel’s (in the event applicable) name, email address, other contact details, and payment details. | This information will be processed for the purpose of performing our contract with you as well fulfilling our legitimate interests. We use this information to provide you with the Services you have requested. We will use your email address in order to send you needed information related to the Services and our business engagement. In addition, we may send you marketing and promotional messages, offers and discounts. You can opt out unsubscribe through a designated link in the email that we will send or contacting us at: privacy@truvid.com Please note that if you choose to unsubscribe from direct marketing, we may still hold your contact details and contact you for updates regarding your use if the Services or any other relevant Service-related information. The direct marketing information is processed subject to legitimate interest. |
Users of Truvid Service
In the event you are an end user of our Partners ("End Users") interacting with our Media Player, we will not collect or store any information about you, however, our Partners using our Services, may collect certain information for the purpose or displaying personalized ads. This Personal Information may include online identifiers and other behavioral related information, including IP address and mobile related identifiers (for example Advertising ID and IDFA). Please refer to the privacy policy of our Partner (i.e., the website or content you were browsing) you are interacting with for more information. Please note that this Privacy Policy refers solely to our privacy practices. We do not control nor monitor nor have any responsibility to our Partners’ privacy practices. Notwithstanding the above, for certain information regarding opt out alternatives (whether you are using desktop or mobile device), please see the Cookies paragraph below.
HOW WE COLLECT INFORMATION
Depending on the nature of your interaction with the Site and Services, we may collect information as follows:
• Automatically – we may use cookies (as elaborated in the section below) or similar tracking technologies to gather some information automatically.
• Provided by you voluntarily – we will collect information if and when you choose to provide us with the information, such as through a physical agreement, contact us communications, etc. all as detailed in this Privacy Policy.
SHARING INFORMATION WITH THIRD PARTIES
We will not share any Personal Information it collects with any third party. Other than under the following circumstances:
(i) Authorized Disclosures. We may disclose your Personal Data to third parties when you consent to a particular disclosure. Please note that once we share your information with a third party, that information becomes subject to the third party’s privacy practices.
(ii) Compelled Disclosures. We will share your information, solely to the extent needed to comply with any applicable law or permitted by it, regulation, legal process or governmental request (e.g., pursuant to law enforcement inquiries, subpoenas or court orders), or when we believe, in good faith, it is required in order to enforce our policies (including our policies and agreements) including investigations of potential violations thereof or to detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues. In addition, we will share your information, solely to the extent needed to establish or exercise our rights to defend against legal claims or to prevent harm to the rights, property or safety of us, our users, yourself or any third party or for the purpose of collaborating with law enforcement agencies or in case we find it necessary in order to enforce intellectual property or other legal rights.
(iii) Agents / Service Providers. We may disclose Personal Data to our trusted agents and service providers so that they can perform requested services on our behalf (among others, as detailed in the “Cookies and other technologies” Section above). These entities are prohibited from using your personal information for any purposes other than providing us with requested services.
(iv) Business Transfers. 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 Privacy Policy.
(v) Online Identifiers. We may share Online Identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Site, as well as to calculate payments and detect fraud, security or technical issues in connection with the operation of the Company.
(vi) Explicit Consent. Pursuant to your explicit approval prior to the disclosure.
For avoidance of doubt, we may transfer and disclose or otherwise use Non-Personal Information or information which is linked to anonymous random identifiers or information that is aggregated in a non-identifiable way, at its own discretion.
COOKIES POLICY
When you access or use the site, we may use “cookies” (or similar technologies), which store certain information on your device (i.e., locally stored) and which will allow us to as enhance your experience of the site. The use of cookies is a standard industry-wide practice. A "cookie" is a small piece of information that a website or assigns and stores on your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes such as allowing you to navigate between pages efficiently and making the interaction between you and our Site quicker and easier, as well as to help customize your experience and for advertising purposes (including personalized advertising). You can find more information about cookies at www.allaboutcookies.org. For more information about cookies and your controls in this regard, please review our Cookie Policy
DATA RETENTION
We retain the information we collect as long as it remains necessary for the purposes set forth above, all in accordance with applicable laws, or until an individual expresses a preference to opt-out. We may at our sole discretion, delete or amend information from our systems, without notice to you, once we deem it is no longer necessary for such purposes.
USER 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 provide you with the ability to exercise certain choices, rights and controls in connection with your information. Please review our Privacy Rights Policy regarding your rights under applicable law. 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 and send it to our privacy team at: privacy@truvid.com.
SECURITY
We take great care in implementing and maintaining the security of our Services and your information. We employ industry standard procedures and policies to ensure the safety of individuals’ information and prevent unauthorized use of any such. We have implemented technical, physical and administrative security measures to protect the Personal Information. In addition, we limit access to your information on our servers. The data collected by us is stored in the AWS data servers, for more information regarding the data security provided by AWS, please see: https://aws.amazon.com/security/. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site and Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
PROTECTING CHILDREN
The Site is intended for individuals over the age of sixteen (16). Therefore, we do not intend and does not knowingly collect directly Personal Information from children under the age of sixteen (16) and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Site.
CHANGES TO THE PRIVACY POLICY
We reserve the right to change this Privacy Policy at any time, so please re-visit this page frequently. In the event of any substantial change of this policy, we will make reasonable efforts to post a clear notice on the site. Such substantial changes will take effect seven (7) days after such notice was provided on the site, dashboard or sent by email. Otherwise, all other changes to this Privacy Policy are effective as of the stated “Last Revised”. Note to California Residents: Notwithstanding the above, as required under the, this Policy will be reviewed and updated every 12 months, as required under the CCPA.
DATA TRANSFER
We may store or process your Personal Information in the EU, United States or in other countries. Thus, any information you provide to us may be transferred to and processed in countries other than the country from which you accessed our Service. We will take appropriate measures to ensure that your Personal Information receives an adequate level of data protection upon its transfer.
ADDITIONAL INFORMATION AND CONTACT US
If you have any questions (or comments) concerning this Privacy Policy, you are welcome to send us an email at: privacy@truvid.com or and we will make an effort to reply within a reasonable timeframe.
DATA PROTECTION OFFICER
If you have any requests regarding the data collected under this Privacy Policy, including without limitation, requests to remove, delete, amend, modify or transfer the data, please contact our Data Protection Officer at: dpo@truvid.com. Please include your name, address and email address in any correspondence so that we can respond to your inquiry or request.
