Last Updated: May 2018
- 1. INTRODUCTION
- 2. INFORMATION THAT WE COLLECT
- 3. HOW WE USE THE INFORMATION THAT WE COLLECT
- 4. SHARING AND DISCLOSURE OF THE INFORMATION THAT WE COLLECT
- 5. USER CHOICE AND ACCESS REGARDING PERSONAL DATA
- 6. DATA COLLECTION FROM CHILDREN
- 7. SECURITY
- 8. INTEGRATION OF THIRD PARTY PLATFORMS AND SERVICES
- 9. RETENTION OF YOUR PERSONAL DATA
- 11. ACCURACY OF INFORMATION PROVIDED
- 12. CONTACT US
- 13. DATA STORAGE, TRANSFER AND PROCESSING
We collect personal information or other information about you when you use the Vevo CTV App. The information we may process depends upon your interaction with us. The key types of personal data that we may process include the following:
- Account Log-In Information. If you have previously registered for a Vevo account, you may have the ability to log in to your account (i.e., with your email address and password) on the Vevo CTV App to access your previously created playlists and preferences.
- Contact Information for Customer Service or Privacy Requests. If you contact us with a customer service or privacy-related request, we may use the information that you provide us (e.g., email address or phone number) to process and respond to your request.
- To fulfill our contractual obligations under an existing agreement with you, including:
- To communicate with you about your account, the Vevo CTV App and Vevo; and
- To deliver content on the Vevo CTV App.
- To meet and/or fulfill our legitimate interests, including:
- To manage our business needs, such as monitoring, analyzing, modifying and improving the Vevo CTV App’s functionality and performance;
- To prevent fraud and abuse on and unauthorized access to the Vevo CTV App;
- To provide localized content on the Vevo CTV App based on the country in which you are located (as determined based on your IP address), and to personalize and/or otherwise customize what you see when you use the Vevo CTV App (for example, by providing you access to your saved playlists if you log in to your Vevo account);
- To provide localized advertising to support the delivery of content on the Vevo CTV App based on your general geographic location (as determined based on your IP address);
- To respond to your questions or other requests;
- To conduct research for marketing/promotional purposes and to provide anonymous and aggregated reporting (i.e., reporting that does not identify you and cannot be combined with other information to identify you) for internal use and use by external clients, business partners and other third parties; and
- To accumulate and report aggregated, de-identified, statistical information in connection with the Vevo CTV App and user activity.
- To comply with our regulatory and legal obligations or to enforce our legal rights, including:
- To meet reporting requirements (e.g., filing tax forms);
- To retain documents and information related to a legal action;
- To report data breaches or unauthorized access to the Vevo CTV App.
We will not share your personal data or information with others except in the following circumstances:
- Our Group Entities: We may disclose your personal data to other group entities that are affiliates and/or subsidiaries, owners or parents of Vevo in accordance with our internal policies or administrative or business practices.
- With Your Consent: If we do not process your personal data in accordance with our legitimate interest or based on a contractual obligation we have with you, we may share or disclose your personal data if you provide us with your affirmative consent. We will obtain consent from you prior to sharing your personal data with third parties for their marketing purposes and enabling your use of any location-based services.
A. Privacy Requests. You may contact us about privacy preferences and learn more about your choices with respect to advertising on the Vevo CTV App by sending an email to us at email@example.com detailing your privacy request. If you ask Vevo to stop using your personal data, we will honor that request, provided that we may retain a record of such information as necessary to comply with applicable law and we may continue to use your contact information to respond to your requests. If you continue to use the Vevo CTV App, we may continue to use your IP address to determine the country in which you are accessing the Vevo CTV App in order for content to be displayed within the Vevo CTV App. You always have the right to access, review and correct the personal data you have provided.
B. EU Citizens and Residents. If you are an EU citizen or reside in the EU, you may have certain rights with respect to the personal data you provided to us. To the extent permitted by applicable data protection laws, you may:
- Access or modify your personal data;
- Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
- Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
- Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
- Under certain circumstances, have your personal data transferred to another company; or
- Withdraw any consents that you have previously provided to allow us to process your personal data.
If you wish to exercise any of these rights please contact us at firstname.lastname@example.org. Please note that some requests may require you to verify your identity.
http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm for information from the Federal Trade Commission about protecting children’s privacy online.
We also limit access to the Vevo CTV App to our own employees, contractors, operators, service providers and those individuals who are authorized for the proper handling of and have a business need to access such information. We request that our third party contractors and service providers follow similar standards of security and confidentiality as those followed by Vevo. However, it is possible that third parties may unlawfully intercept or access transmissions or private communications despite our efforts to prevent same and we therefore make no guarantees regarding the security of user information. While we are dedicated to securing your personal data and our systems and the Vevo CTV App, you are responsible for securing and maintaining the privacy of your credentials (e.g., user name and password) and verifying that personal data we maintain about you is accurate and current. We are not responsible for protecting any personal data that we share with a third-party (e.g., cable/satellite television provider) based on an account connection that you have authorized.
Mail: Vevo LLC
Attn: Privacy Matters
4 Times Square, 25th Floor
New York, New York 10036
Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.
Please note that such transfers may also be necessary in order to perform our obligations under a contract with you, to fulfill a request made by you, to meet a legal or regulatory obligation and/or through obtaining your express consent. If you make transactions with parties outside the EEA or Switzerland or connect the Vevo CTV App with platforms outside the EEA or Switzerland, we are required to transfer your personal data with those parties in order to provide the Vevo CTV App to you. If you wish to gain more information about such transfers, please contact us at email@example.com.
If you access the Vevo CTV App in any country outside the European Union, the data controller is Vevo LLC. If you access the Vevo CTV App in Germany, the data controller is:
Vevo Germany GmbH
Rosenthaler Str. 51
10178, Berlin, Germany
If you access the Vevo CTV App in any country in the EU other than Germany, the data controller is:
Vevo (UK) Limited
1st Floor Palladium House
1-4 Argyll Street
London W1F 7TA, United Kingdom
Copyright © 2018 Vevo LLC