Privacy Policy

Welcome to Truvid, an online video platform (“Platform”), provided to you by Truvid Inc. (the "Company", "we", or "us"). We also operate the website https://www.truvid.com, its subdomains and its related features (“Website”). In this Policy, the Website, Platform and any service, content material or feature made available thereon are collectively referred to as the “Services”). This Policy is integrated into and forms part of our Terms of Use ("Terms").

We are dedicated to protecting your privacy rights and making our practices regarding the processing of your Personal Data more transparent and fair. This Privacy Policy (“Policy”) was designed to help you understand the information we collect, store, use and share, and it applies whenever you visit or interact with our Services. Please note that parts of this Policy may not be applicable to you, depending on the jurisdiction in which you reside and the applicable laws.

We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time, pursuant to this policy and our terms. you are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the best experience of using our Services.

1. What Types of Data Do We Collect?

We collect Personal Data from visitors and users of our Services, as well as from other data subjects whose details we collect during the provision of our Services or their operation, such as job candidates ("you"). "Personal Data" means any information which could potentially allow your identification with reasonable means as well as "personal information" or any similar terms used under applicable privacy laws. This section sets out how and when we collect and process Personal Data about you.

a. 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.

b. Account Information

If you choose to register an account with our Services, we collect your full name, email address, phone number, birthdate and username. If you choose to log in, access or otherwise connect to the Services through a social networking service (such as Facebook, Twitter, Instagram, etc.), we collect your user ID and username associated with that social networking service, as well as any information you make public using that social networking service or that the social networking service allows us to access.

c. Online Identifiers

When you access our Services, we may, either directly or indirectly collect your IP address and other online or device identifiers (for example Advertising ID and IDFA). We may also collect technical non-Personal Data.

d. Recruitment

In the event you are interested in joining our team, and wish to apply for a job with us you will be required to provide us your name, email address, and CV.

e. Registration Information

We may collect Personal Data 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.

f. Third Party Information Regarding Interaction with Our Services

g. In the event you are an end user of our partners interacting with our media player, our partners using our Services (and consequently us), may collect certain information for the purpose or displaying personalized ads. This Personal Data may include online identifiers and other behavioural related information, including IP address and mobile related identifiers (for example Advertising ID and IDFA Please note that this Privacy Policy refers solely to our privacy practices. We do not control, monitor nor have any responsibility to our partners’ privacy practices). Please refer to the privacy policy of the relevant partner (i.e., the website or content you were browsing) you are interacting with for more information. For information regarding opt out options (whether you are using desktop or mobile device), please see the Tracking Technologies paragraph below.

2. Personal Data

In the event you are an end user of our partners interacting with our media player, our partners using our Services (and consequently us), may collect certain information for the purpose or displaying personalized ads. This Personal Data may include online identifiers and other behavioural related information, including IP address and mobile related identifiers (for example Advertising ID and IDFA Please note that this Privacy Policy refers solely to our privacy practices. We do not control, monitor nor have any responsibility to our partners’ privacy practices). Please refer to the privacy policy of the relevant partner (i.e., the website or content you were browsing) you are interacting with for more information. For information regarding opt out options (whether you are using desktop or mobile device), please see the Tracking Technologies paragraph below.

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage:

2.1. Why Do We Process Your Personal Data?

This section explains for what purposes we use your Personal Data and outlines the legal bases that underlie our usage:

Purpose	Legal basis
Support. We may use our your personal data, such as your email, name, phone number or other means of communication to provide you with the support or information you have requested. We also collect (from our Website directly, or indirectly from our partners' properties) certain online identifiers as described above, as part of our Services to such partner. We will use the email address to send needed information related to the Services and our business engagement. We may process online identifiers during the provision of or services.	The legal bases for processing your data is the performance of our contractual obligations with you; your consent; and our legitimate interests. Our legitimate interests in this case are provision of our Services including support.
Payments. We may collect your payment details in order to provide you with our services.	The legal bases for processing this data are the performance of our contractual obligations, and your consent.
Improve our Services. We collect your IP address for the purposes of usability, quality, functionality and effectiveness of our Services, including debugging to identify and repair errors and undertake internal research for technological development and demonstration.	The legal basis for processing this data is your consent and our legitimate interest. Our legitimate interests in this case are providing and improving our Services and performing analytics on the use of our Services
Recruitment. We collect the names, email addresses and CV of those who are interested in joining our team. We do not request or require sensitive Personal Data concerning religion, health, sexual orientation, or political affiliation in connection with recruiting. We will use the information provided solely for communication, to manage our recruiting and hiring processes, and for compliance with corporate governance and legal and regulatory requirements. If hired, the information may be used in connection with employment and corporate management.	The legal bases for processing this data is your consent, and our legitimate interests. Our legitimate interests in this case include performing a proper recruiting process for our candidates, record keeping and the protection from potential legal claims.
Auditing related to counting ad impressions of unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with relevant specification and standards.	The legal basis for processing this data is your consent (for example, as obtained through our or our partners' cookie consent mechanisms), and our legitimate interest. Our legitimate interest in this case is providing you with our Services, including the provision of content that better corresponds with your interests, providing monetization services to our partners, and the performance of analytics, security and fraud detection, and campaign reporting.
Integrity. We process certain information about you and your usage of our Services in order to keep the integrity and security of our Services, prevent fraud, identify your identity and enforce our policies.	The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users.
Compliance with applicable laws; assistance to law enforcement agencies. We process your Personal Data in order to comply with our legal obligation under applicable laws.	The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations and assisting law enforcement agencies.

3. Tracking Technologies

When you access or use the Services, we may use “cookies” (or similar tracking 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 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.

Below is a list of useful links that can provide you with more information on how to manage your cookies:

• Google Chrome;

• Mozilla Firefox;

• Safari (Desktop);

• Safari (Mobile);

• Android Browser; and

• Microsoft Edge

You can learn more and turn off certain third-party targeting and advertising cookies by visiting the following third-party webpages:

• The Interactive Advertising Bureau (US);

• The Interactive Advertising Bureau (EU); and

• European Interactive Digital Advertising Alliance (EU)

If you are accessing our services through a mobile device app, you can withdraw your consent to personalized advertising experience on your device at any time by using your device settings as follows:

• On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the “Limit Ad Tracking” setting or disabling the “Allow Apps to Request to Track” permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the “Allow Apps to Request to Track” setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).

• On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

4. To Whom Do We Disclose your Data?

(a) 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.

(b) Agents and 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 Policy” Section above). These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.

We will share your information, solely to the extent needed to comply with any applicable law, 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.

(d) Auditors and advisers:

we share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.

(e) Business Operation:

We may share online identifiers collected by us (as detailed above), for the purpose of operating our business and providing the Services, as well as to calculate payments and detect fraud, security or technical issues in connection with the operation of the Company.

(f) Mergers and acquisitions:

We will transfer, sell, or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.

4.1 Disclosures of Personal Data

We do not "sell" your personal data, as this term is defined under US privacy laws.

In the 12 preceding months, we have shared or disclosed the following categories of your personal data:

Category of personal data

Personal data Categories of third parties Personal data was disclosed, shared, or sold

Identifiers Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, address, telephone number. Service providers & data aggregators; business partners Personal data was disclosed, shared.

Internet or other electronic network activity data

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Service providers & data aggregators; business partners Personal data was disclosed, shared

Professional or employment-related data Current or past job history or performance evaluations. Service providers (such HR services providers and recruitment agencies) Personal data was disclosed

Geolocation data (non precise) Physical location or movements, including the location of your device location or movement. Service providers & data aggregators; business partners Personal data was disclosed, shared

4.2 In the 12 preceding months, we have collected personal data from the following categories of sources:

a. Consumer directly;

b. Advertising networks;

c. Internet service providers;

d. Data analytics providers;

e. Social Networks; and

f. Data Brokers

5. Marketing and advertising

We use your personal data ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, ads, products, services, websites, and applications which relate to our affiliated companies or our business partners (collectively: “Marketing Affiliates”), which we believe may interest you.

You can decline receiving further marketing offers from us or from our business partners and Marketing Affiliates at any time, by contacting us at privacy@truvid.com. Please note that even if you unsubscribe from our marketing-mailing list, we can continue to send you service-related updates and notifications.

6. Your rights

6.1 Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your personal data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights:

(a) Rights of access to your Personal Data

You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

(b) Right of data portability

you have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.

You have the right to request rectification of your Personal Data in our control in the event that your believe the Personal Data held by the Company is inaccurate, incomplete or outdated.

(d) Right of deletion/erasure

You have the right to request that the Company erase or delete Personal Data held about you at any time.

(e) Right to restriction or objection to processing

You have the right to request that the Company restrict or cease to conduct certain Personal Data processes at any time.

(f) Right to withdraw your consent

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.

(g) Right to limit use and disclosure of your sensitive Personal Data

You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.

(h) Right not to be subject to automated decision making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

(i) Right to Opt-Out of the Sale or share of Personal Data

In the event that we sell or share your Personal Data for behavioural advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Data. After you opt-out, we may continue disclosing some Personal Data with our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services is working correctly and securely, providing aggregate statistics and analytics, and preventing fraud.

(j) Right to non-discrimination

you have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

(k) Right to lodge a complaint and appeal our decisions

all requests, complaints or queries may be addressed to the Company to the following email address: privacy@truvid.com. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Please note that these rights are not absolute, and may be subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

We provide you with the ability to exercise certain choices and controls in connection with our treatment of your Personal Data, depending on your relationship with us. You may exercise any or all of your above rights in relation to your Personal Data by filling out the Data Subject Request form available here and send it to our privacy team at privacy@truvid.com.

6.2 Requests Metrics

In the past 12 months, we did not receive any requests to delete, to know, to opt-put of selling, sharing or to limit use and disclosure of sensitive Personal Data.

We will publish metrics regarding the number of such requests we have received, complied with (in whole or in part) or denied, and also the median or mean number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to July 1st of the following year) once we receive such requests, and to the extent required by us under US Privacy laws.

6.3 Authorized Agent

(a) You can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

i. The authorized agent is a natural person or a business entity; and

ii. You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

(b) The request must:

i. Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and

ii. Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.

(c) We will only use Personal Data provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Making a verifiable consumer request does not require you to create an account with us.

7. Transfer of Personal Data

We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various jurisdictions around the world, including (but not limited to) the European Economic Area, United Kingdom and United States, for the purposes detailed in this Policy. We will take appropriate measures to ensure that your Personal Data receives an adequate level of data protection upon its transfer.

8. How We Protect Your Data?

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 Data.

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.

9. Minors

Our Services are not designed for and we do not knowingly collect or process Personal Data from minors under the age of majority (as determined under applicable laws where such individual resides; “Minors”). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor without verification of parental or legal guardianship's consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, then please contact us immediately through the contact details available below.

10. Retention

We will retain your Personal Data for as long as necessary to provide our Services or until an individual expresses a preference to opt-out, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined to take into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy or amend outdated, unused information at the earliest reasonable time.

11. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy. 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.

Notwithstanding the above this Policy will be reviewed and updated every 12 months, as required under the CCPA.

12. Controlling Version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

13. Data Protection Officer

The Company has appointed a “Data Protection Officer” who is responsible for matters relating to privacy and data protection. 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.

14. IAB Transparency & Consent Framework

Truvid participates in the IAB Europe Transparency & Consent Framework and complies with its Specifications and Policies. Truvid’s identification number within the framework is 862.