1.1 VIDEY INC, operator of the VIDEY PLAY platform ("Company," "we," "us," or "our"), is committed to protecting your privacy and ensuring transparency regarding our data practices. This Privacy Policy complies with applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA), California Privacy Rights Act (CPRA), and other state privacy statutes. This Policy explains what personal information we collect, how we use it, your rights regarding your data, and how to exercise those rights.
1.2 This Policy applies to all users, including Content Producers and Subscribers, and is part of our Terms of Use. By accessing or using the VIDEY PLAY platform, you consent to the practices described in this Policy.
1.3 If you are a California resident or a resident of another state with privacy laws, you have specific rights outlined in Section 7 of this Policy.
2.1 We collect the following categories of personal information:
2.2 We collect personal information through: (a) direct interactions (registration, payment, support requests); (b) automated technologies (cookies, pixels, analytics); (c) third-party sources (payment processors, fraud prevention services); and (d) publicly available sources.
2.3 Children's Privacy: The VIDEY PLAY platform is not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13 without verifiable parental consent, we will delete such information. For users ages 13-17, we comply with applicable age-gating requirements and obtain necessary consents.
3.1 We process personal information for the following purposes:
3.2 Legal Basis: We process personal information based on: (a) your consent; (b) contractual necessity to provide services; (c) compliance with legal obligations; (d) protection of vital interests; (e) legitimate business interests (fraud prevention, security, analytics); and (f) public interest or governmental authority.
3.3 Sale or Sharing of Personal Information: We do not sell personal information in the traditional sense. However, we may share information with third parties for cross-context behavioral advertising purposes, which may constitute "sale" or "sharing" under CCPA/CPRA. You have the right to opt-out of such sharing (see Section 7).
4.1 We may disclose personal information to the following categories of recipients:
4.2 All service providers are contractually obligated to maintain the confidentiality and security of personal information and are prohibited from using it for purposes other than providing services to us.
4.3 We do not sell, trade, or rent personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties except as permitted or required by law, with your consent, or as described in this Policy.
4.4 Do Not Track: We honor "Do Not Track" browser signals where applicable. However, please note that not all tracking mechanisms can be disabled by Do Not Track signals.
5.1 We may initiate internal investigations to investigate alleged violations of our Terms of Use or applicable law, with the objective of preserving platform integrity and user security.
5.2 Such procedures are conducted with appropriate confidentiality measures. Complaints are treated confidentially, and we limit disclosure of the complainant's identity to the extent permitted by law.
5.3 Individuals under investigation have the right to access information necessary to respond to allegations, while we take measures to protect the privacy of complainants and third parties.
5.4 We retain records and evidence related to investigations for the period necessary to defend our rights and comply with legal obligations, not to exceed the periods permitted under law.
6.1 We retain personal information for as long as necessary to fulfill the purposes for which it was collected, including:
6.2 Retention periods vary by data category and purpose. After the retention period expires, we delete or anonymize personal information, except where law requires continued retention.
6.3 We do not retain personal information longer than reasonably necessary to achieve the purposes for which it was collected.
7.1 Right to Know: You have the right to request what personal information we have collected about you, the categories of sources, our purposes for collection, and the categories of third parties with whom we share information.
7.2 Right to Access: You may request access to your personal information in a portable and readily useable format.
7.3 Right to Delete: You may request deletion of personal information collected from you, subject to certain exceptions (e.g., information necessary to complete transactions, comply with legal obligations, or detect security incidents).
7.4 Right to Correct: You may request correction of inaccurate or incomplete personal information.
7.5 Right to Opt-Out: You have the right to opt-out of (a) the sale of personal information, and (b) the sharing of personal information for cross-context behavioral advertising. To exercise this right, click the "Do Not Sell or Share My Personal Information" link on our website or contact us using the information below.
7.6 Right to Limit: You have the right to limit our use and disclosure of sensitive personal information to purposes necessary to provide or maintain the services you expect or as permitted by law.
7.7 Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights. We will not deny you goods or services, charge different prices, or provide a different quality of service based solely on your exercise of privacy rights, except as permitted by law.
7.8 How to Submit a Request: To exercise any of these rights, please submit a request through one of the following methods:
7.9 Verification of Requests: To protect your privacy and security, we will verify your identity before responding to access or deletion requests. Verification may require providing account information, email verification, or other reasonable means of confirmation. Authorized agents may submit requests on your behalf if you provide written authorization.
7.10 Response Timeline: We will respond to verifiable requests within forty-five (45) days. If we require additional time, we will notify you and explain the reason for the delay. You have the right to appeal our decision if we deny your request.
8.1 We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These measures include encryption, firewalls, secure authentication, and regular security assessments.
8.2 Payment Information Security: We do not store complete credit card numbers. Payment processing is handled by compliant third-party payment processors that maintain PCI DSS compliance.
8.3 Limitations: While we employ industry-standard security measures, no system is completely secure. We cannot guarantee absolute security. Users are responsible for maintaining the confidentiality of their passwords and account information.
8.4 Data Breach Notification: In the event of a data breach involving unencrypted or unredacted personal information, we will notify affected individuals and relevant authorities in accordance with applicable state and federal laws without unreasonable delay.
9.1 "Sensitive personal information" includes social security numbers, financial account information, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic data, biometric data for identification purposes, health information, and sex life information.
9.2 We limit our collection, use, and disclosure of sensitive personal information to purposes necessary to provide or maintain the services you expect, or as otherwise permitted by law. We will not use sensitive information for purposes of targeted advertising, cross-context behavioral advertising, or other non-essential purposes without your explicit consent.
10.1 We use cookies, web beacons, pixels, and similar tracking technologies to enhance user experience, analyze usage patterns, and deliver personalized content. These technologies may collect information about your browsing activities across different websites.
10.2 You can control cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of our platform.
10.3 California consumers may have additional rights regarding third-party tracking. We honor opt-out preferences as described in your browser's Do Not Track settings.
11.1 Our platform may contain links to third-party websites and services that are not operated by us. This Policy does not apply to third-party services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party services before providing personal information.
12.1 Your personal information may be transferred to, stored in, and processed in countries other than your country of residence, including Brazil and other jurisdictions. These jurisdictions may not provide the same level of data protection as your home country. By using our platform, you consent to the transfer of your information to jurisdictions outside your country of residence.
13.1 We may update this Privacy Policy at any time. Material changes will be notified to you via email or through prominent notice on our platform. Your continued use of the platform following such notice constitutes your acceptance of the revised Policy.
13.2 We encourage you to review this Policy periodically to stay informed about how we protect your privacy.
14.1 California Residents (CCPA/CPRA): In addition to the rights described above, California residents have the right to: (a) know whether their information is sold or disclosed and to whom; (b) delete personal information subject to certain exceptions; (c) opt-out of the "sale" or "sharing" of personal information; and (d) correct inaccurate information. California residents may designate an authorized agent to make requests on their behalf.
14.2 Virginia, Colorado, Connecticut, and Utah Residents: Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), and Utah (UCPA) have similar rights to access, delete, correct, and opt-out of the sale of personal information. These rights are available upon request.
14.3 For state-specific requests or inquiries, please contact us using the information below.
California Residents - Shine the Light: Under California Civil Code Section 1798.83, you have the right to request information about the categories of personal information we share with third parties for their direct marketing purposes. To submit such a request, please contact us at the email address above.
Appeal Process: If we deny your privacy rights request, you have the right to appeal our decision. To appeal, please contact us with details of your original request and explanation of why you believe our response was incorrect.
Last Updated: 2024-04-05
This Privacy Policy is effective as of the date listed above and applies to all users of the VIDEY PLAY platform. By accessing or using our platform, you acknowledge that you have read and understood this Privacy Policy.