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Privacy Policy SI

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Provision of our Services; support; service announcements; push notifications; analytics, surveys and research; protecting our interests; enforcing of policies; We may use your Personal Data, such as your name and email address, for operational purposes, for example, responding to your inquiries. In other instances we may, for example, use your Personal Data to send you notifications and communications if you opted in and/or accepted to receive them from us, or if they are relevant to your use of our Services (such as service announcements).

The legal bases for Processing this data are the performance of our contractual obligations towards you; your consent (for example, when you provide Personal Data); compliance with our legal obligations; and our legitimate interests. Our legitimate interests in this case are enforcing our policies, protection against fraud and misuse of our Services.

Payments. We collect from our third-party payment processors certain information about your payment instruments for the purpose of completing any transaction requested by you, and sending to you statements, invoices, or receipts.

The legal bases for Processing this data are the performance of our contractual obligations; the protection of our legitimate interests, in this case enforcing our policies and preventing misuse of our Services; and compliance with legal obligations to which we are subject.

Improve our Services. We collect and analyze information about you and your usage of our Services to improve the usability and effectiveness of our Services.

The legal bases for Processing this data are our legitimate interests, in this case - providing and improving our Services. Where analytics data containing personal data is collected through cookies and similar Tracking Technologies (as further described below) we rely on your consent, where required.

Marketing and Advertising; We may use Tracking Technologies (which may collect Personal Data) in order to provide you with personalized advertisements when you visit our Services.

The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests.

Third Party Advertising and Data Segmentation; We may share your personal data with third party ad networks and data segmentation solution companies to enrich, segment or optimize your data for marketing and advertising purposes of ourselves and our business partners.

The legal bases for processing this data are your consent (where required) and our legitimate interests. Our legitimate interests in this case are providing you with tailored Services, content and advertisements that better correspond with your interests, and assisting our business partners to do the same. As explained below, where applicable, you will have the option to opt-out from such data processing.

Integrity. We may process certain information about you and your usage of the Service in order to keep the integrity and security of the Services, prevent fraud, identify your identity and enforce our policies.

The legal bases for processing this data are your consent (where required), compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services and the safety of our end-users.

Compliance with applicable laws, legal and regulatory requirements.

We may be required to collect, retain, or share your Personal Data, under applicable laws.

In the course of using the Services, we may ask you to provide us with certain Personal Data to provide and improve the Services, to contact or identify you, to enable you to access certain parts of the Websites, and as otherwise indicated in this Policy. We may collect the following Personal Data about you:

We also collect data about the use of our Services and the characteristics and activities of users, in order to operate it and improve it. We may collect the following "Technical Data":

If you choose to use Amazon Alexa Skills or Google Assistant in connection with the Services, Amazon and Google will process your personal data via their voice processing technologies, by which they collect audio through the microphone on your device(s) to effectuate an instruction or request by you using Amazon Alexa Skills or Google Assistant. Please be aware that your use of Amazon Alexa Skills or Google Assistant may provide Amazon and Google with access to and use of information associated with your use of their device, including the audio you provide, and you should carefully review their privacy policy and terms of use (to learn more about their data processing, please visit Google's policies, here and here; and Amazon's policies: here and here). If we combine Personal Data with Technical Data, the combined data will be treated as Personal Data. Further Personal Data will only be stored and processed if you voluntarily provide it to us, e.g. through a contact form.

When you visit or access our Services we use (and authorize third parties to use) pixels, cookies, events and other technologies. Those allow us to automatically collect information about you, your device and your online behavior, in order to enhance your navigation in our Services, improve our Websites' performance, perform analytics and customize your experience on it. In addition, we may merge information we have with information collected through these tracking technologies with information we may obtain from other sources and, as a result, such information may become Personal Data.​

To learn more about our Tracking Technologies please visit our Cookie Policy page. Additionally, residents of the EEA or other applicable jurisdictions may use our Cookie Settings tool to learn more and to change their preferences.

We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, or disclosure of your Personal Data. Your data is stored on secure servers and isn't publicly available. We limit access of your information only to those employees or partners on a "need to know" basis, in order to enable the carrying out of the agreement between us.

While we seek to protect your information to ensure that it is kept confidential, we cannot absolutely guarantee its security. You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorized use. You should also be aware that there is always some risk involved in transmitting information over the internet. While we strive to protect your Personal Data, we cannot ensure or warrant the security and privacy of your Personal Data or other content you transmit using the Services, and you do so at your own risk.

We will retain your Personal Data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, trading information, account opening documents, communications and anything else as required by applicable laws and regulations.

We operate globally, thus any information that we collect, disclose or share, including your Personal Data, can be stored and processed in various other jurisdictions around the world ("Other Jurisdictions"), including (but not limited to) the European Economic Area, United Kingdom, United States and Canada, for the purposes detailed in this Policy. As a result, your Personal Data may be subject to the laws of such foreign jurisdiction and may be accessible without notice to you by the courts, law enforcement, and national security authorities of that jurisdiction. 

EU users, please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

To the extent that the GDPR or UK GDPR are applicable, we will only transfer or share your Personal Data to data recipients:

You can obtain more information about our policies and practices with respect to the use of service providers located in Other Jurisdictions by contacting us as described below under the "How to Contact Us" heading.

If you reside within the European Union or the UK, you may request to:

  1. Receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

  2. Receive a copy of Personal Data you directly volunteer to us in a structured, commonly used and machine-readable format.

  3. Request rectification of your Personal Data that is in our control.

  4. Object to the processing of Personal Data by us.

  5. Request to restrict processing of your Personal Data by us.

  6. Request erasure of your Personal Data.

  7. Lodge a complaint with a supervisory authority.

However, please note that these rights pertain to EU and UK residents only, are not absolute, and may be subject to our own legitimate interests and regulatory requirements. ​If you, as EU of UK resident, would like to exercise any of the rights mentioned in this section, please refer to the section 9B below.

If you reside in the EEA or UK, we will be the controller of your Personal Data provided to, collected by or for, or processed by us in connection with our Services. 

All requests, complaints and queries should be addressed to us by submitting a verifiable consumer request to our email address: dpo@minutemedia.com (please provide the required details as per Section 15 below).

We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them. To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority. 

Our representative in the European Union is Lionheart Squared (Europe) Ltd., 2 Pembroke House, Upper Pembroke Street 28-32, Dublin, D02 EK84 Ireland, and their email address is: MinuteMedia@lionheartsquared.eu.

Our representative in the United Kingdom is 385-389 Oxford St. London W1C 2NB and their email address is: dpo@minutemedia.com.

In addition, you can exercise your rights via dpo@minutemedia.com, where you can submit a verifiable user request.

Only you or a person legally authorized to act on your behalf may make a consumer request related to your Personal Data ("Request").The Request must:

For the purposes of this section, the "CCPA" shall mean the California Consumer Privacy Act, Cal. Civ. Code § 1798.100 et seq., as amended by the California Privacy Rights Act of 2020, and the regulations promogulated thereunder.

In the preceding 12 months, we have collected, disclosed, and/or sold the following categories of Personal Data:

Identifiers

Full name, email address, postal address, social media identifiers, photos, IP address, UDID, Advertising Ids

Affiliated Companies

Payment Processors

Advertising Networks

Data Analytics Providers

Payment Processors

ID Companies

Data Segmentation Providers

Personal Data Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Full name, billing information, credit card number (collected directly by our payment processors)

Affiliated Companies

Payment Processors

Cloud Services

Internet or Other Electronic Network Activity Information

Information on a consumer's interaction with a website, application, or advertisement

Affiliated Companies Advertising Networks

Data Analytics Providers

Cloud Service

ID Companies

Data Segmentation Providers

Geolocation Data

Physical location (non-precise)

Affiliated Companies Advertising Networks

Data Analytics Providers

Cloud Service

ID Companies

Data Segmentation Providers

We may share or transfer Personal Data to third parties as assets that are part of a merger, acquisition, bankruptcy or other transaction in which the third party assumes control of all or part of Minute Media. Such transfer will be handled according to the requirement of the CCPA and shall not be regarded as a sale of Personal Data under the CCPA.



In the 12 preceding months, we have collected the above-mentioned categories of Personal Data from either of the following categories of sources:

The CCPA provides consumers with specific rights regarding their Personal Data. This section describes your CCPA rights and explains how to exercise those rights.

You may request, up to two times in a 12 months period, that we disclose to you the categories and specific pieces of Personal Data that we have collected about you, the categories of sources from which your Personal Data is collected, the business or commercial purpose for collecting your Personal Data, the categories of Personal Data that we disclosed for a business purpose, any categories of Personal Data about you that we sold, the categories of third-parties with whom we have shared your Personal Data, and the business or commercial purpose for selling your Personal Data, if applicable.

You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.

You have the right to request us to rectify your Personal Data place in our control in the event that you believe your Personal Data is inaccurate, incomplete or outdated.

You have the right to request that we delete any Personal Data collected from you and retained by us, unless an exception applies. Once we receive and confirm your verifiable consumer request, we will delete (and where necessary and relevant, direct our service providers, subcontractors, and consultants to delete) your Personal Data, unless an exception applies.

You have the right to request that we will restrict or cease to conduct certain Personal Data processes at any time.

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.

You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

If we sell your Personal Data, you have the right to submit a request to opt-out of the sale of your Personal Data. You may change your decision at any time and permit us to sell your Personal Data.

If you do not want us to sell your Personal Data to third parties, please click on the "Do Not Sell My Personal Information" link located on the homepages of our Brand Websites for residents located in California.

After you opt-out, we may continue to share some Personal Data with our partners (who will function as our service providers in such instance) to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and/or preventing fraud. If you access this site (or app) from other devices or browsers, visit the links below from those devices or browsers to ensure your choice applies to the Personal Data collected when you use those devices or browsers.

Additionally, although clicking the "Do Not Sell My Personal Information" link will opt you out of the sale of your Personal Data for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Data or all interest-based advertising. If you would like more information about how to opt-out of interest-based advertising in desktop and mobile browsers on a particular device, please visit https://optout.aboutads.info/?c=2&lang=EN and https://optout.networkadvertising.org/.

You may also download the AppChoices app at http://www.aboutads.info/appchoices to opt-out in connection with mobile apps, or use the platform controls on your mobile device to opt-out.

You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

Unless permitted by the CCPA, in connection with you exercising your aforementioned rights, we will not:

Please note that these CCPA rights are not absolute and requests are subject to any applicable legal requirements, including legal and ethical reporting or document retention obligations.

We publish metrics regarding the number of requests we have received, complied with (in whole or in part) or denied, and also the median number of days in which we responded to such requests, in the previous year (these metrics are compiled annually and refer to the period between July 1st of the previous year to April 20th of the following year):

Requests to Delete

35

Up to 72 hours from the day of applicable request

Requests to Know

Up to 72 hours from the day of applicable request

Requests to Opt Out of Sale

206,768

Immediate

If you reside in California, you can use an authorized agent to make a Request to exercise your right under applicable laws on your behalf if:

The Request must:

Making a verifiable Request does not require you to create an account with us. If you would like to exercise any of any of the rights mentioned in this section, please contact the email address mentioned below: dpo@minutemedia.com (please provide the required details as per Section 15 below).

The following part of this Policy complements the general part of the Policy and addresses the specific disclosure requirements under the Brazilian Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").

The processing of your Personal Data is not a condition for the use our Services. However, parts of our Services may not be available without registration and/or payment, which involve the processing of Personal Data.

If you reside in Brazil, you have the following rights under LGPD:

If you would like to exercise any of any of the rights mentioned in this section, please contact the email address mentioned below: dpo@minutemedia.com (please provide the required details as per Section 15 below).

If you are resident in Canada, you may have certain rights (including those described below) with respect to your Personal Data that we Process. To exercise any of your privacy rights, please contact us as set out below under the "How to Contact Us" heading.

Our goal is to respond to a verifiable consumer request within 45 days (for US residents), or 30 days (for UK and EU residents) of its receipt. If we require more time, we will inform you of the reason and extension period in writing within the initial response period. We will deliver our written response, electronically. If reasonably possible, we will provide your Personal Data in a format that is readily useable and should allow you to transmit the information without hindrance.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

In case of rejection, the response we provide will explain the reasons for which we cannot comply with your request.

Under certain jurisdictions, some of the aforementioned rights may apply as well. Please contact us using the contact details provided below and we would make our best efforts to assist with any questions or requests.

We do not knowingly collect or solicit Personal Data from Minors (as determined under the applicable laws where the individual resides; "Minors"). By accessing, using or interacting with our Services, you certify to us that you are not a Minor. If we have collected Personal Data from a Minor without verification of parental or legal guardianship consent, we will delete that information upon discovery. 

If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.

This Policy is subject to changes from time to time, in our sole discretion. The most current version will always be posted on our Websites (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. In the event of material changes, we may also provide you with a notice. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. All translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact our Data Protection Officer ("DPO") using the details provided below.​

Kindly specify: (a) the nature of your request, (b) your country of residence, and (c) the name of the Services (website/product/application) subject of your request.



Email: dpo@minutemedia.com‍​

Please be advised that dpo@minutemedia.com is designated solely for privacy related inquiries of our users, and we reserve the right not respond to any non-privacy inquiries that are sent via the DPO email address. For any non-privacy inquiries, please see send an email to contactus@minutemedia.com.

Upon receiving your request, and according to legal obligations to which we are subject, we will first need to verify your request and therefore we may ask you to provide us with additional verification details, as needed. Following our verification process, we will respond to your request within the timeframe required under applicable laws.

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