Our primary goals in collecting information are to provide and improve access to our Platform, to administer your use of the Platform, and to enable you to enjoy and easily navigate our Platform.
(a) Access to your Information. If you access our Platform, we may collect certain information that can be used to identify you, such as your name, address and email address, telephone number, credit card information, and the like (“PII”).
(b) Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies and Web Beacons to collect certain information.
“Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Platform for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Platform, to monitor how many visitors view our Platform, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
“Log Data” means certain information about how a person uses our Platform (a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, the web page that a User was visiting before accessing our Platform, the pages or features of our Platform to which a User browsed and the time spent on those pages or features, search terms, the links on our Platform that a User clicked on and other statistics. We use Log Data to administer the Platform and we analyze (and may engage third parties to analyze) Log Data to improve, customize and enhance our services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Platform is used.
(c) Information Sent by Your Mobile Device. We collect certain information that your mobile device sends when you use our Platform, like a device identifier, user settings and the operating system of your device, as well as information about your use of our Platform.
We will not share any PII that we have collected from or regarding you except as described below:
(a) Information Shared with Our Services Providers. We may engage third-party service providers to work with us to administer and provide access to our Platform and services. These third-party service providers have access to your PII only for the purpose of performing services on our behalf.
(b) Information Disclosed in Connection with Business Transactions. Information that we collect from our users, including PII, is considered to be a business asset. Thus, if we are acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, some or all of our assets, including your PII, may be disclosed or transferred to a third party acquirer in connection with the transaction.
(c) Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a third party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
We offer you choices regarding the collection, use and sharing of your PII and we’ll respect the choices you make. Please note that if you decide not to provide us with the PII that we request, you may not be able to access all of the features of the Platform.
(b) Modifying Your Information. If you want us to delete your PII, please contact us at firstname.lastname@example.org with your request. We will take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.
Our Platform does not have the capability to respond to “Do Not Track” signals received from various web browsers.
We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your PII) from unauthorized access, use or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information.
Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide your PII to us, we may transfer your PII to the United States and process it there.
Where Viddles is a controller of data (e.g., when collected via the Platform), the legal basis is either legitimate interest or consent depending on the type of information subject to processing and the information we receive from upstream partners. We may also process data for the performance of a contract with you. Where we rely upon legitimate interest, we have assessed the processing is not high risk, does not involve the processing of sensitive data and will not violate fundamental human rights. With respect to providing the Platform to users, Viddles is a processor of data and the legal basis for processing such data is determined by each user.
Viddles primarily stores PII in the United States, in the cloud, and on our servers. To facilitate our global operations, we may transfer and access such information from around the world.
Viddles participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. We are committed to subjecting all PII received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website: https://www.privacyshield.gov/welcome. A list of Privacy Shield participants is maintained by the Department of Commerce and is available at: https://www.privacyshield.gov/list.
With respect to PII received or transferred pursuant to the Privacy Shield Frameworks, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose PII in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If your PII was received in reliance on either Privacy Shield Framework and you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider JAMS, at no cost to you, at https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration after other dispute resolution procedures have been exhausted.
The GDRP affords additional rights to EU data subjects. Those rights include the right to complain to EU Supervisory Authorities and the right to access, receive a copy of, correct, delete, block, and limit or object to the processing of your PII processed by Viddles. Where otherwise permitted by applicable law, EU and Swiss data subjects may contact us at email@example.com to request access to, request to receive, port or restrict processing, seek rectification or request erasure of PII held about you by Viddles. Such requests will be carried out in accordance with applicable laws. Although Viddles makes good faith efforts to provide you with access to your PII, there may be circumstances in which Viddles is unable to provide access, including for example, where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If Viddles determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Viddles will take reasonable steps to verify your identity before granting access to or making any changes to your PII.
As a data processor for our users, Viddles processes data in connection with the Platform, which may include PII on behalf of our users. We will not use, share, distribute, or reference any such PII except as provided in the applicable agreement between us and our users, detailed at http://www.truupit.com/terms, or as may be required by law.
California residents may request and obtain from us, once a year, free of charge, a list of third parties, if any, to which we disclosed their PII for direct marketing purposes during the preceding calendar year and the categories of PII shared with those third parties. If you are a California resident and wish to obtain that information, please submit your request by sending us an email at firstname.lastname@example.org with “California Privacy Rights” in the subject line.