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VIDEOLEVELS PRIVACY POLICY

This Privacy Policy explains (together with our General Terms and Conditions and Cookie Policy) how we treat the personal information that we collect from you or that you provide to us. Please read this Privacy Policy carefully to understand our approach and our processing of your personal data and how we might use it. This policy may be changed, and all the changes and additions will be announced at the bottom of this document, along with information about the date on which the changes were implemented, so please read this policy from time to time.

We are processing your personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.

We will use your personal information in relation to the purpose for which they were collected and not further in a manner that is incompatible with those purposes.

For processing your personal data, we may use processors, in this case, we shall use only processors providing sufficient guarantees to implement appropriate technical and organizational measures in such a manner that processing will meet the requirements of Data Protection Laws and ensure the protection of the rights of the data subject.

This Privacy Policy, including the General Terms and Conditions and Cookie Policy, applies when you are using, have used or wish to use:

web platform videolevels.com and to all sub sites, applications and services related to it
third party (“Merchant”) media solutions built on videolevels.com platform that can vary with name, domain name or other characteristics.

CONTACT DETAILS

We are Babahh Innovation OÜ (hereinafter “us”, “our”, “Videolevels”) and we are registered in Estonia with a registration number 14113082, address: Tatari 58, 10134 Tallinn, Estonia.

For questions, comments and requests regarding this Privacy Policy, please send an email to info@videolevels.com .

INFORMATION THAT WE MAY COLLECT FROM YOU

If you order Videolevels services ("Services"), we collect some or all the personal information listed below. The information that we collect depends on the circumstances. For example, if you connect to any of Videolevels.com packages on a monthly subscription basis or use Videolevels.com platform to distribute your media content , we may collect and use most of the information specified below. If you only use our Service on one occasion by One-off Payment, we will collect more limited information.

Information that we may collect are:

Identifying information, such as first and last name, gender, date of birth or personal code.

Contact information,such as email address, phone number and address, we may record the correspondence address if you contact us.

Payment and financial information, such as card type, number, expiration date, credit card security code, registered address or account information for PayPal.

Any other information, provided at the time of registration for use of our Website, connection to our Services or requesting additional services from us. We also may request information from you when you report a problem with our Website, on special offers or when you enter a contest.

User information, that you provide for research purposes (ratings, reviews, responses to inquiries and other requests), that you don’t actually need to respond to.

Tracking and preference information,, such as details of your visits to our Website, including, but not limited to, IP address, data traffic, location data and other communication data, whether this is required for our own billing purposes or not, and also the resources that you have access to. We also collect information about your use of our Website through cookies and other similar technologies. You can read more about this in Cookies policy. We may also collect information about your use or viewing habits, such as:

what kind of programmes you watch;
how you use media services, such as pause the programme, skip a programme, advance or rewind;
whether you save programmes to watch later;
whether you skip the ads, if they are presented on Videolevels;
your purchase preferences, for example, responses to ads or campaigns.

We may supplement the information we receive from you and about your use of our Services with publicly available information about you, as well as with information we receive from third parties. We can also get information about your use of our websites, products and services including media solutions provided by Merchants via Videolevels.com platform. This could, for example, include information that we collect from other people in your household and information that we receive from third parties (for example, information about your use of our Services to make your service more personal and recommend media content you may like).

In this Privacy Policy, personal information means information that can be used to identify you. Non-personal information is information that can’t be used to identify a person. We may collect, use, transfer, or disclose non-personal information for any purpose.

You can request that no personal information is disclosed, but often the personal information that we request is necessary for us to provide our Services. If we do not have the information we need, we will not be able to provide our Services.

Please note, that you are solely responsible for correctness and completeness of the personal data you provide to us.

THE USE, PURPOSE AND LEGAL BASIS OF PROCESSING

We process the information we collect from you on the basis of the performance of a contract or in order to take steps prior to entering into a contract or on the request of the data subject, when you have given us your consent or for compliance with a legal obligation or for legitimate interests, for managing customers and providing our Services in the following ways:

to identify you or your representative;
to validate payment;
to provide our Services to you and to help to remove the malfunctioning;
to ensure that content on our Website is presented to you and your device in the most efficient way;
to conduct surveys in order to improve your interaction with the Service;
to provide order and invoice information to you;
to communicate with you regarding your subscription, your account or purchase of Services;
to allow you to use the Videolevels application for social media, given that you select it, in accordance with your security settings;
to send push notifications to you with the content that you subscribe to;
to notify you about changes in the Services;
to record and store phone calls with the aim of obtaining these voice recordings for the purposes of verifying the declarations or transactions made by us and you, and for your better service;
to assess and prevent potential commercial risks or losses for the provision of the Service;
for the liability and protection from legal claims or proceedings (incl. violation of the contract and / or for the transfer of data related to debt to persons authorized by us to process such data (lawyers, debt collection service, etc.);
to perform credit checks.

We process the information we collect from you on the basis of on the request of the data subject or when you have given us your consent or for the purpose of the legitimate interests pursued by us, for processing your personal information, including profiling, for marketing purposes and for receiving personal offers from Videolevels and Merchants via email, SMS, telephone or other electronic means, in the following ways:

to provide offers, news, information, products or services that you request from us or which we believe may interest you;
to send our newsletter to you, which may also contain offers, news, information, products or services of Videolevels or Merchants which we believe may interest you. Please note that you can always unsubscribe from the newsletter by changing your account settings in your account or by following the link for unsubscribing in the message;
to make your experience of our Services more personal, based on your usage and viewing, for example, to recommend other movies, TV series and sports programmes and other content that may interest you or customize ads for your interests.

We also may use your information or allow Merchants or selected third parties to use your data, which is specified in more detail below (see Disclosure of your information).

PROFILING

Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

We also may use profiling for marketing and to make your experience of our Services more personal, which is based on the performance of the contract or in order to take steps at the request of you prior to entering into a contract, or when you have given us your consent.

WHERE AND FOR HOW LONG WE STORE YOUR PERSONAL DATA

Any information you provide to us is stored on our secure servers. All payment transactions are encrypted using industry-standard technology. If we have given you (or you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We urge you not to disclose this password to anyone. If possible, you should log out from public or shared devices after every single visit. If you sell or return a computer or a device on which you were able to view Videolevels, you should first log out and disable the device. If you do not store your password or your device safely, or if you do not log out or disable your device, subsequent users can gain access to your account and your personal information.

The transfer of information via the internet is not yet completely secure. Although we do our best to protect you, we cannot guarantee the security of your information and we cannot take responsibility for unauthorized access to it. All information transfer to our Website is at your own risk. Once we have access to your information, we use rigorous methods and security measures to try to prevent unauthorized access to this information.

Your personal information will not be processed when it is no longer necessary. Retention period can be based on contracts with you, our legitimate interest or applicable law.

TRANSFER TO THIRD COUNTRIES

nformation we collect from you may be transferred to and stored outside the European Economic Area ("EEA"). It can also be processed by staff working for us or for one of our suppliers, acting outside the EEA. Such personnel might work on the processing of your order, your payment details and performance of support services. By entering your personal data, you agree to this transfer, storage and processing. We will take all necessary actions that are reasonable to ensure that your data is treated securely and in accordance with this Privacy Policy, and in addition, data transfer can take place, when the third country ensures adequate level of protection or is certified under the EU-US Privacy Shield Frameworks. On your request we can provide more information about which data are transferred to third countries.

DISCLOSURE OF YOUR INFORMATION

We may disclose your personal information, on your consent, to any Merchant in order for that company to provide information on goods and services that might interest you. We or such companies may contact you for this information by email, letter, telephone or SMS. Merchants, that have access to your personal data, follow practices in accordance with this Privacy Policy.

We may disclose your personal information to third parties if we have reasonable grounds to believe that disclosure of the information is necessary, for example, if:

we sell or buy any business or assets, we may disclose your personal information to the prospective buyer or seller of such business or assets;
Videolevels or a substantial part of its assets are acquired by a third party, personal information about Videolevels customers will be one of the transferred assets;
if we are required to disclose or share your personal information to comply with any legal obligation, regulation, legal process or governmental request, or to enforce or apply our General Terms and Conditions, including investigation of potential violations. This includes exchanging information with other companies and organizations in order to prevent fraud and reduce credit risk, detect, prevent, or otherwise tackle illegal or suspected illegal activities, lack of security or technical issues.

We may use collected information to monitor the use of our Services in order to help us improve our Services, and we may provide such collected information to third parties, such as content providers that we work with, or advertisers. This collected information does not contain personal information.

We may also use third party companies to perform services for us, for example, to provide infrastructure and IT services (including, but not limited to, data storage and monitoring of streaming quality), process credit card transactions, provide customer services, collect debt analysis and improve data as well as customer inquiries and perform other statistical analyses. These companies may have access to your information in order to perform services. We do not authorize these companies to use or disclose your personal information except to provide the services we require.

If you do not want to receive our newsletter, you can change your contact preferences at any time on the page called "My Account". You can also exercise this right by contacting us at info@videolevels.com at a time suitable for you. Please note that you cannot unsubscribe from certain correspondence from us, for example, communications concerning your account transactions or updates on our Services that you subscribe to.

CONNECTING YOUR VIDEOLEVELS ACCOUNT TO YOUR ACCOUNT ON SOCIAL MEDIA

You can link your account on social media, e.g. Facebook, to Videolevels. If you decide to connect your account on social media to Videolevels, we will collect some information about this account, which can be used in the manner described above.

We do not take responsibility for the content that comes from services that do not belong to Videolevels or for information you share with or send to those services. If you use third party services, you should read their own privacy policies to determine how they will treat the information they collect about you.

ACCESS TO OTHER SITES

On some occasions our Website may contain links to and from websites that are owned by Merchants, our network partners, advertisers and subsidiaries. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any liability for their policies. Please read their privacy policies before you provide any personal information on these sites.

DATA SUBJECT RIGHTS

You have the following rights concerning your personal data:

to access information held about you. You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed by us, and, where that is the case, access to the personal data and information provided by law;
to rectification of inaccurate personal data concerning you;
to erasure of personal data, for example if data are no longer necessary or if the processing of your data is based on your consent, but you have withdrawn your consent, and there is no other legal ground for the processing;
to restriction of processing, for example, when we analyse, whether you have the right to the data erasure;
to receive the personal data concerning you, which you have provided us and which we are processing under your consent or under contract and by automated means, in a commonly used and machine-readable format and you have the right to transmit those data to another controller (data portability);
to object to processing of your personal information, which is based on legitimate interests, including profiling, unless we demonstrate compelling legitimate grounds for the processing; or right to object for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing;
to withdraw your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you.

IP ADDRESSES

We may collect information about your computer including, if such information is available, your IP address, operating system and browser type as well as connection speed and internet provider, for our system administration and for reporting collected information to our advertisers. This is statistical data about our users' activity on the Internet and pattern which do not identify any individual.

We will also check your residency by accessing your IP address and verify your mobile phone number, by sending you a verification code, which you have to fill in while finalizing registration.

CHANGES IN OUR PRIVACY POLICY

All future changes that we make in our Privacy Policy will be announced on this page, see above. When appropriate, you will also be notified about the changes via email, in accordance with our General Terms and Conditions. All changes take effect immediately excluding already existing subscribers, for whom the changes apply 30 days after they are announced, unless stated otherwise.

RIGHT TO COMPLAIN A SUPERVISORY AUTHORITY

You have the right to lodge a complaint with a supervisory authority (www.aki.ee) if you consider that the processing of your personal data infringes your rights or the law.

DATA PROTECTION OFFICER

Videolevels has appointed an internal data protection officer for you to contact if you have any questions or concerns about our personal data policies or practices. The data protection officer´s contact information are as follows:

Tatari 58, 10134 Tallinn, Estonia, referred to “Data protection officer”, email: support@videolevels.com. Visit our Cookie Policy for details on how we use cookies and our General Terms and Conditions.

This Privacy Policy applies from the 25th of May 2018.