Last Updated: October 5, 2016
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
6. DATA COLLECTION FROM CHILDREN
8. YOUR CALIFORNIA PRIVACY RIGHTS
9. INTEGRATION OF THIRD PARTY PLATFORMS AND SERVICES
11. ACCURACY OF INFORMATION PROVIDED
12. CONTACT US
13. DATA STORAGE, TRANSFER AND PROCESSING
A. Registration Information. When you register to use the Services, we may ask you to provide certain information, including your name, username, password, e-mail, date of birth, gender, address and music, artist or band preferences.
B. Payment Information. If you make any purchase on or through the Services, your payment information (e.g., credit or debit card type, number and expiration date) and related information (e.g., physical address) may be collected by us and/or our third party payment processors.
D. User Posts. You may have the ability to use the Services to communicate with other users of the Services and post comments to or otherwise interact with certain aspects of the Services that are available to the public and/or other users. We may collect any information you submit, post or provide in the course of such activities.
F. Third Party Platform Information. If you access the Services via your Third Party Platform account (e.g., by logging in to the Services using your Third Party Platform account credentials) and/or integrate your Vevo account with your Third Party Platform account, we may collect certain information from the Third Party Platform, such as your username and other information you provided to the Third Party Platform in connection with your account (e.g., name, country, date of birth, gender and e-mail address). You can learn more about adjusting your settings and preferences with respect to Third Party Platforms in Section 5.A. below.
G. Information Collected By Advertising Service Providers. The Services may also use third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Service Providers”) that may employ cookies and similar technologies to collect information about your interaction with the Services, your web browsing activity and your device, including your IP address, device type and other identifiers, browser type, web pages visited, non-precise location information, and information about your interaction with advertisements. Please see Section 5.D. below for further information on the types of information collected by Third Party Advertising Service Providers, how such information may be used and your choices pertaining to such collection and use.
3. HOW WE USE THE INFORMATION THAT WE COLLECT. Subject to the controls and preferences you may set with respect to certain types of information and communications (as described in Section 5 below), your information may be used for various purposes, including:
• To provide the Services and any services or products that you request or purchase in connection with the Services, and to contact you regarding the administration of any features or functions of the Services;
• To send you marketing and promotional e-mails;
• To allow you to participate in the community and other features of the Services;
• To respond to your questions or other requests;
• To personalize the Services and/or otherwise customize what you see when you visit and use the Services (for example, by providing personalized or localized content, features, recommendations and advertising on the Services);
• To provide customized, localized and/or targeted advertising on third party websites and services, as further described in Section 5.D. below;
• To save your user account, registration and profile data and other information (so you do not have to re-enter it each time you visit or use the Services);
• To track your return visits to, and use of, the Services;
• To conduct research for marketing/promotional purposes and to provide anonymous reporting (i.e., that does not identify you) for internal and external clients, business partners and other third parties;
• To accumulate and report aggregated, de-identified, statistical information in connection with the Services and user activity;
• To determine which features and services users like best to help us operate the Services, enhance and improve our services and display advertising and marketing information; and
B. Non-Personal Information. We may share, disclose and/or sell certain information about you, your device and your interaction with the Services with Third Party Advertising Service Providers in an anonymized, de-identified format, as further described in Section 5.D. below. We may also share, disclose and/or sell to third parties aggregated data regarding our users’ access to and use of the Services. To the extent that your information is included in such aggregated data, it will be in an anonymized, de-identified format that does not personally identify you.
D. User Content. Your Vevo user profile (including your profile picture and your list of friends or connections on the Services) will be set to “private” by default, meaning that it will not be shared with other users of the Services, unless you adjust your privacy settings to allow such sharing. However, the Services may include features that allow you to connect on the Services with people you know, by accessing your contact list, address book or friends on Third Party Platforms (if you choose to make such information available to us), and such features may allow other users to see your name and/or username, even if your user profile is set to “private”. Such features may also allow other users to send you a request to connect with you on the Services, and, if you accept such requests, your user profile will be shared with such users, even if your user profile is set to “private”. In addition, you may have the ability to share other content that you make available on the Services (such as your playlists or videos that you have viewed) with other users of the Services and Third Party Platforms. In such cases, certain information associated with such content may also be disclosed, such as your username. Subject to your user account preferences and privacy settings (as further described in Section 5.A. below), we may disclose any content that you make available on the Services.
E. Service Providers. We use third-party service providers to assist us in efficiently providing the full range of content, activities, services, features and functions offered by the Services, and we may disclose your personal and other information to these service providers solely to the extent necessary for them to provide such services to us and our affiliates. These service providers may temporarily store certain information on their servers, but they may only use your information to provide Vevo with a specific service. We will not authorize them to use your information for any other purpose and will require them to agree to keep your information secure and confidential.
A. User Account Privacy Settings. We provide you with the ability to adjust certain privacy, permission and user account settings via the Services. For example, you can control whether your user profile is visible to the public and/or to other users of the Services. You can also control whether or not you want to share certain information (such as your playlists or videos that you have viewed) on Third Party Platforms. You also may be able to adjust certain privacy, permission and user account settings by responding to request alerts or notifications that may be presented to you on your device prior to or following the collection of the relevant information or by navigating to the settings, account or privacy section (as the case may be) of your device or the applicable Third Party Platform and limiting certain Service functionality (e.g., location services, etc.). Please be aware that if you limit the collection of certain information, you may not be able to use all of the features and functionality of the Services.
B. Privacy Requests. You may also change certain privacy preferences (e.g., choose to cease receiving certain communications or ask us not to share your personal information with a particular third party) by sending an email to us at email@example.com detailing your privacy request. If you ask Vevo to stop using your personal information, 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 contact you about your Services-related transactions and to respond to your requests, as well as your IP address to determine the country in which you are accessing the Services. Other privacy preferences (e.g., hiding your user profile, deactivating your user account, etc.) may be made by modifying your user account settings on the Services, your device and/or the applicable Third Party Platform. You always have the right to access, review and correct the personal information you have provided and generally you may review, update or delete certain information collected by the Services at any time by accessing your user account as described herein.
C. Opting Out of Marketing and Promotional Communications. You can unsubscribe or opt out of receiving marketing and promotional communications by either following the specific instructions included in such communications or by sending an email to us at firstname.lastname@example.org detailing your privacy request. Please note that opt-out and unsubscribe requests may not take effect immediately and may take a reasonable amount of time to receive, process and apply, during which time your information shall remain subject to the prior privacy settings. Additionally, you should be aware that any information provided to third parties prior to your election to opt out or unsubscribe cannot be retrieved or rescinded by us unless required by applicable law, and you cannot retroactively opt out or unsubscribe with respect to such third parties. Also, please note that we may still send you emails regarding changes to our policies and/or the features and functionality of the Services or in connection with a purchase via the Services or other purposes specifically relating to your account and/or use of the Services. We may also have features that allow you to submit information, questions or feedback to us. In those instances, we may retain your emails and other information you submit to us for purposes of responding to you, for our internal purposes, and to help us to serve you better.
D. Interest-Based Advertising Opt-Out. The Services may use Third Party Advertising Service Providers to collect information about your interaction with the Services. These Third Party Advertising Service Providers may employ Tracking Technologies to gather information regarding your use of the Services, your web browsing activity and your device, such as your IP address, device type and other identifiers, browser type, web pages visited, non-precise location information, and information about your interaction with advertisements. This information is collected in an anonymized, de-identified format and does not personally identify you. Third Party Advertising Service Providers may combine your information relating to your use of the Services with information relating to your other online activities over time and across different websites (including those operated by third parties) and devices. The information collected or received by Third Party Advertising Service Providers may be used to show you targeted advertisements for products and services that you might be interested in, on the Services and on third party websites and services. This information may also be used to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you. If you would like to learn more about interest-based advertising or opt out of receiving interest-based advertisements, please visit the following websites of the Digital Advertising Alliance (DAA) and Network Advertising Initiative (NIA), respectively: www.aboutads.info/consumers/; www.networkadvertising.org. Please note that, in order to opt out of receiving interest-based advertising on the Vevo mobile application, you may need to adjust your mobile device’s settings.
6. DATA COLLECTION FROM CHILDREN. Vevo recognizes the need to adequately protect the privacy of all if its users, especially children. The Services are not intended for or directed at children. We do not knowingly collect personal information from children under 13. Please visit http://www.ftc.gov/bcp/edu/pubs/consumer/tech/tec08.shtm for information from the Federal Trade Commission about protecting children’s privacy online.
7. SECURITY. While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal information. We also limit access to the Services by our own employees, contractors, service providers and those individuals who are authorized for the proper handling of 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.
8. YOUR CALIFORNIA PRIVACY RIGHTS. If you are a resident of the State of California, we provide you with information on how to exercise your disclosure choice options such as your right to opt out or opt in for use of your personal information by third parties (such as advertisers) for marketing purposes. Therefore, pursuant to the California Civil Code, we are not required to maintain or disclose a list of the third parties that have received your personal information for marketing purposes during the preceding year. If you are a California resident and wish to request information about how to exercise your third party disclosure choices, please send a request by email to our Privacy Administrator at email@example.com or by postal mail to Vevo LLC, vevo.com, c/o Privacy Administrator, 4 Times Square, 25th Floor, New York, NY 10036, Attn: Your California Privacy Rights. All requests must be labeled “Your California Privacy Rights” in the email subject line or on the envelope or post card. For all requests, please clearly state that the request is related to “Your California Privacy Rights”, include your name, street address, city, state, zip code and e-mail address (your street address is optional if you wish to receive a response to your request via email) and indicate your preference on how our response to your request should be sent (email or postal mail). We will not accept requests via the telephone or by fax. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.
Mail: Vevo LLC Attn: Privacy Matters 4 Times Square, 25th Floor New York, New York 10036
13. DATA STORAGE, TRANSFER AND PROCESSING. When you have provided consent and/or to the extent permitted by applicable privacy or data protection laws, your personal information may be transferred to, stored, processed and/or used by Vevo on servers in the United States and/or the locations and servers of any Vevo affiliate and/or service provider that transfers, stores, processes or uses personal information on Vevo’s behalf. When this involves transferring your personal information from the European Economic Area to areas outside the European Economic Area, Vevo will seek to provide an adequate level of data protection according to EU standards. If you access the Services in any country outside the European Union, the data controller is Vevo LLC. If you access the Services in Germany, the data controller is:
Vevo Germany GmbH
Rosenthaler Str. 51
10178, Berlin, Germany
If you access the Services 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 © 2016 Vevo LLC