1. INTRODUCTION.

    Vevo recognizes that its users value their privacy and we take your privacy seriously. This privacy policy (“Privacy Policy”) explains our privacy practices, including what types of information we collect from you and how we may use it, our rights to share and disclose such information to third parties and how you can review and modify information that you provide to us and your preferences regarding our use and disclosure of such information. Please review our
    Terms of Use Agreement (“Terms of Use”), which governs your use of the Vevo CTV App. Any capitalized terms that are not defined in this Privacy Policy shall have the meaning given in the Terms of Use.

    This Privacy Policy only applies to the information collected by Vevo LLC, Vevo (UK) Limited, Vevo Germany GmbH and any of their respective affiliates (collectively, “Vevo”, “we”, “our” or “us”) or any third parties acting with our authorization or otherwise provided to us by third parties about you, in each instance, in connection with your use of the Vevo-branded television application (also commonly referred to a “cable television app”, “CTV app” or “living room app”) made available via certain third party television connected, digital streaming devices and television subscription services, including Amazon Fire, Apple TV, Sky and Virgin TV (collectively and individually, the “Vevo CTV App”). This Privacy Policy applies regardless of whether you are accessing the Vevo CTV App as a registered user, television service subscriber or otherwise.

    We will either rely on our legitimate interest or our need to perform under a contract to collect, store, use and process your information or you will be asked to affirmatively consent to our processing (i.e. collection, use and storage) of your information, all in accordance with the terms and conditions of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, then please do not use the Vevo CTV App.
  1. HOW WE USE THE INFORMATION THAT WE COLLECT.

    We may process your personal data (depending on your interaction with us) for a variety of reasons that are permitted under data protection laws and in accordance with this Privacy Policy, which may include the below purposes, and any other purposes disclosed at the time that you provide us with such data. Note that the legal bases outlined below are required to be included under EU data protection laws, but are not required to be included if you do not reside in the EU.

    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 enforace our legal rights, including:
    • To meet reporting requirements (e.g., filing tax forms);
    • To retain documents and information related to a legal action;
    • To enforce the Terms of Use; and
    • To report data breaches or unauthorized access to the Vevo CTV App.

    With your consent. If you have allowed us to process your personal information based on consent, you can withdraw your consent to such uses of your personal data that rely on consent as a legal basis to processing at any time by following the steps in Section 5 in this Privacy Policy.
  1. SHARING AND DISCLOSURE OF THE INFORMATION THAT WE COLLECT.

    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.

    • Third Party Service Providers: e may share your information with other carefully selected third party operators, advertising networks, data exchanges, traffic measurement service providers and other service providers for the purpose of (1) assisting with facilitating transactions on or through the Vevo CTV App, (2) providing advertisements within the Vevo CTV App to support the delivery of content via the Vevo CTV App (3) providing information technology and customer service assistance, and (4) providing, delivering, offering, supporting, administering, maintaining and enabling the Vevo CTV App (including providing a full range of content, activities, services, features and functions offered on or in connection with the Vevo CTV App). We request that service providers maintain commercially reasonable standards of security and confidentiality and must agree to keep such information secure and confidential in line with this Privacy Policy. Please note that we are not responsible for the actions of service providers, third party operators or other third parties, nor are we responsible for any additional information you provide directly to any third parties. Some information that we provide to third party service providers may be in an aggregated and anonymized form and will not personally identify you.

    • Corporate Transactions or Events: If Vevo sells all or part of its business or makes a sale or transfer of all or a material part of its assets or stock or is otherwise involved in a merger, joint venture, transfer, corporate reorganization or other disposition of its business, Vevo may transfer your information to the party or parties involved in the transaction as part of that transaction, and such party or parties may use the information for the purposes set forth in, and in accordance with the terms of, this Privacy Policy.

    • Pursuant to Law, Rule or Regulation: We may share or disclose your information with other parties as we deem necessary or appropriate under applicable law, rule or regulation. Examples of these purposes include: to respond to requests from public, governmental and regulatory authorities, to comply with court orders, to obtain legal remedies or limit our damages, to enforce this Privacy Policy or the Terms of Use, and to protect the rights, safety and/or property of you, our employees or others.

    • 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.
  1. USER CHOICE AND ACCESS REGARDING PERSONAL DATA.

    1. 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 mailto:privacy@vevo.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.

    2. 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:
  1. SECURITY.

    While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect the personal data that we collect, use and/or store, which are consistent with applicable privacy and security laws. These policies and measures are designed to prevent against loss, misuse, unauthorized access, modification and disclosure and unlawful destruction of your personal data.

    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.
  1. DATA STORAGE, TRANSFER AND PROCESSING.

    Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and some of our subsidiaries and affiliates, servers, vendors and service providers may not be located in your jurisdiction and may be located outside of the European Economic Area and Switzerland. If you are an EU citizen or resident in the EU, we will transfer your personal data to the United States in accordance with EU data protection law requirements by using model contractual clauses that have been approved by the European Commission or other appropriate means.

    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
    privacy@vevo.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 the EU, the data controller is:
    Vevo (UK) Limited
    1st Floor Palladium House
    1-4 Argyll Street
    London, W1F 7TA, United Kingdom

This document is the sole statement of the Vevo CTV App’s Privacy Policy and no summary, restatement or other version thereof, or other privacy statement or policy, in any form, including, without limitation, machine-generated, is valid.

This Privacy Policy was last modified on the date indicated above and is effective immediately.

Copyright © 2018 Vevo LLC