Privacy Policy

Last Updated: May 2018

  1. INTRODUCTION
  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 REGARDING PERSONAL DATA
  6. DATA COLLECTION FROM CHILDREN
  7. SECURITY
  8. INTEGRATION OF THIRD PARTY PLATFORMS AND SERVICES
  9. RETENTION OF YOUR PERSONAL DATA
  10. PRIVACY POLICY CHANGES
  11. ACCURACY OF INFORMATION PROVIDED
  12. CONTACT US
  13. DATA STORAGE, TRANSFER AND PROCESSING

 

  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. INFORMATION THAT WE COLLECT.

We collect personal information or other information about you when you use the Vevo CTV App.  The information we may process depends upon your interaction with us.  The key types of personal data that we may process include the following:

 

  • Account Log-In Information. If you have previously registered for a Vevo account, you may have the ability to log in to your account (i.e., with your email address and password) on the Vevo CTV App to access your previously created playlists and preferences.
  • Device ID and IP Address. The Vevo CTV App includes features that automatically pass certain information, which may include the unique device identifier assigned to your television device and the Internet protocol (IP) address, to our Third Party Service Providers in accordance with this Privacy Policy. The Vevo CTV App does not capture or store your device identifier or IP address.
  • Contact Information for Customer Service or Privacy Requests. If you contact us with a customer service or privacy-related request, we may use the information that you provide us (e.g., email address or phone number) to process and respond to your request.

 

  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 enforce 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: We 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 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.

 

  1.             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:
  • Access or modify your personal data;
  • Object, on grounds relating to your particular situation, at any time to the processing of your personal data if the legal ground we are relying on is our legitimate interest or in the public interest;
  • Request that your personal data be erased if it is no longer necessary for the purposes for which it was processed, you have withdrawn consent to, or object to, the processing of such personal data and we meet no other legitimate basis for such processing or it has been unlawfully processed;
  • Restrict the processing of your personal data if you contest its accuracy or the lawfulness of our processing, we no longer need it but you need it for a legal claim or you have objected to its processing and await verification of our legitimate grounds for processing it;
  • Under certain circumstances, have your personal data transferred to another company; or
  • Withdraw any consents that you have previously provided to allow us to process your personal data.

 

If you wish to exercise any of these rights please contact us at privacy@vevo.com.  Please note that some requests may require you to verify your identity.

 

  1. DATA COLLECTION FROM CHILDREN. Vevo recognizes the need to adequately protect the privacy of all of its users, especially children.  The Vevo CTV App is not intended for or directed at children under the age of 16.  We do not knowingly collect personal data from children under the age of 16. If we obtain actual knowledge that we have collected personal data from someone under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data.  If you believe that we have mistakenly or unintentionally collected information from someone under the age of 16, please contact us at privacy@vevo.com.  For users in the United States, please also 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.

 

  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. INTEGRATION OF THIRD PARTY PLATFORMS AND SERVICES. The Vevo CTV App may be linked to, rely on and/or be integrated with Third Party Platforms and other websites, applications, interfaces, services and/or platforms operated by other companies. The Vevo CTV App will also feature advertisements from third parties. Vevo is not responsible for the privacy practices of such websites, applications, interfaces, services and platforms operated by third parties that are linked to, rely on and/or integrated with the Vevo CTV App or for the privacy practices of third party advertising companies.

 

  1. RETENTION OF YOUR PERSONAL DATA. We access, retain, store and use personal data for the least amount of time necessary pursuant to our relationship with you (e.g., to provide you with or access to our products and services), in accordance with our data retention policies and applicable law.  We do not collect more personal data than is necessary to fulfill our obligations to you or at law or for purposes stated in this Privacy Policy. 

 

  1. PRIVACY POLICY CHANGES. From time to time, we may modify this Privacy Policy to reflect industry initiatives, third party requirements or changes in the law, technology, our information collection and use practices or the features and functionality of the Vevo CTV App, and such modifications shall be effective upon posting. When we change this Privacy Policy in a material way, we will endeavor, subject to technological restrictions, to post a notice within the Vevo CTV App along with the updated Privacy Policy.  Your continued use of the Vevo CTV App after we post a revised Privacy Policy (and, where appropriate, notify you of same) signifies your acceptance of the revised Privacy Policy. It is therefore important that you review this Privacy Policy regularly to ensure you are updated as to any changes. We may continue to process your information based on our legitimate interests or in order to fulfill our obligations under a contract and/or may also seek your affirmative consent to the terms of the updated Privacy Policy.  For example, we may ask for your consent before implementing new uses of the personal data that we’ve already collected from you based on such consent, if such new use was not addressed by the privacy policy under which such information was collected or if our legal basis for processing such information changes.

 

  1. ACCURACY OF INFORMATION PROVIDED. It is your responsibility to give us current, complete, truthful and accurate information and to keep such information up to date. We cannot and will not be responsible for any problems or liability that may arise if you do not give us accurate, truthful or complete information or you fail to update such information. We will reject and delete any entry that we believe in good faith to be false, fraudulent or inconsistent with this Privacy Policy.

 

  1. CONTACT US. If you have any questions about our privacy practices, how we handle your personal data or any of the terms or conditions of this Privacy Policy, please feel free to contact us at:

 

Email:      privacy@vevo.com

OR

Mail:        Vevo LLC
Attn: Privacy Matters
4 Times Square, 25th Floor
New York, New York 10036

 

Although we urge you to contact us to find a solution for every concern you may have, you always have the right to lodge a complaint with your competent data protection authority.

 

  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 Germany, the data controller is:

Vevo Germany GmbH

Rosenthaler Str. 51

10178, Berlin, Germany

 

If you access the Vevo CTV App 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

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