Privacy

VIDEO COMMERCE GROUP LTD. PRIVACY POLICY

Last Updated: October 15, 2020

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Video Commerce Group Ltd. (together, “OOOOO” “we”, “our” or “us”) use, collect and store personal data we collect or receive from or about you (“you”) such as in the following use cases:

  • When you browse or visit our website, ooooo.com (“Website”)
  • When you make use of, or interact with, our Website
    1. When you apply to be a Creator on OOOOO
    2. When you ask to be updated
    3. When you contact us
    4. When we process your job application
  • When you make use of, or interact with, our App mobile software application, and any other mobile software application, that we license (each individually, and collectively, the “App”)
    1. When you create an account, log in and use our App as a consumer
    2. When you create an account, log in and use our App as a Creator
  • When you make use of, or interact with, our mobile web pages (“Mobile Web Pages”) for example, when you click through to purchase a product from social media channels or when you click through to the mobile web pages provided by a creator
    1. When you create an account, log in and use our mobile web pages as a consumer
  • When you provide us with your personal data for marketing reasons (e.g. when you attend a marketing event)
  • When we use the personal data of our merchants / brands
  • When we use the personal data of our service providers
  • When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal data” or “personal information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

  1. What information we collect, why we collect it, and how it is used
  2. How we protect and retain your personal data
  3. How we share your personal data
  4. Additional information regarding transfers of personal data
  5. Your privacy rights
  6. Use by children
  7. Interaction with third party products
  8. Log files
  9. Analytic tools
  10. How to contact us

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED


When you browse or visit our Website
, App, or Mobile Web Pages


Specific personal data we collect

Cookies, analytic tools and log files

IP, browser, device model.

For more information, please read our cookies policy available at: ooooo.com/cookies.


Why is the personal data collected and for what purposes?

We collect this information to recommend content and products for you more accurately.

We collect this information to optimize the presentation of the platform based on your hardware and software systems, making it more convenient for you to use our services.

We collect this information to provide a data base for us to pay commissions to creators.


Legal basis (GDPR only, if applicable)

Consent (non essential cookies)

Legitimate interest (essential cookies)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)
  • Appsfly (analytics)

Retention period

For more information, please read our cookies policy available at: ooooo.com/cookies.

Consequences of not providing the personal data

Certain Website features may not be available

Read more about the purposes of each cookie here ooooo.com/cookies.

 

When you make use of, or interact with, our Website


When you apply to be a Creator on OOOOO 


Specific personal data we collect

  • First name
  • Last name
  • Email address
  • Age
  • If you live in the UK
  • Preferences
  • Social media accounts
  • Video
  • Any other information which you choose to provide

Why is the personal data collected and for what purposes?

  • To process your application to be a Creator on OOOOO
  • To communicate with you
  • To send you marketing communications

Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. influencer agreement)

Legitimate interest (e.g., to communicate with you and process your application)

Consent (marketing)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot process your application to be a Creator on OOOOO
  • Cannot communicate with you
  • Cannot send you marketing communications

 

When you ask to be updated


Specific personal data we collect

  • First name
  • Last name
  • Company
  • Email address


Why is the personal data collected and for what purposes?

  • To contact you and keep you updated about our launch
  • To send you marketing communications


Legal basis (GDPR only, if applicable)

Legitimate interest (e.g., to communicate with you about our launch)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. Terms of Use, Brand Agreement)

Consent (marketing)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot contact you and keep you updated about our launch
  • Cannot send you marketing communications

When you contact us (e.g. customer support, need help, submit a request)


Specific personal data we collect

  • Name
  • Email address
  • Company
  • Message
  • Any other information that you decide to provide/supply us


Why is the personal data collected and for what purposes?

  • To receive and respond to your request
  • To customize your experience


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to respond to your request)


Third parties with whom we share your personal data

  • Rex Brown (logistic carrier, order fulfilment)
  • Stripe (Payment provider)
  • Trackingmore (shipping information tracking)
  • Ebanx (Brazil local Payment provider)
  • Google pay/Apple pay (payment provider)
  • Payoneer (settlement)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot receive and respond to your request
  • Cannot customize your experience

When we process your job application


Specific personal data we collect

  • Full name
  • Email address
  • CV / cover letter
  • Any other information that you decide to provide


Why is the personal data collected and for what purposes?

  • To assess you as a candidate
  • To analyze your application


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to assess you as a candidate)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot assess you as a candidate
  • Cannot analyze your application

When you download the App, create an account, log in and use our App as a consumer


Specific personal data we collect

  • Full name
  • Email address
  • Shipping address
  • Billing address
  • Mobile phone number
  • Personal interests
  • IMEII
  • phone model
  • local information from SDK card (access to storage, contacts list, camera and microphone on your phone, access to pictures & videos) and/or SIM card (country, network carrier, phone number)


Why is the personal data collected and for what purposes?

  • To be able to create an account
  • To be able to log in
  • To be able to enjoy features available to registered users only
  • To provide you with access to the App
  • To allow you to make purchases
  • To deliver the purchased items to you
  • To process your payments
  • To suggest products that you may be interested in


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to provide you with access to and use of the App)


Third parties with whom we share your personal data

  • Rex Brown (logistic carrier, order fulfilment)
  • Stripe (Payment provider)
  • Trackingmore (shipping information tracking)
  • Ebanx (Brazil local Payment provider)
  • Avalara (tax solution)
  • Google pay/Apple pay (payment provider)
  • Appsfly (users data analysis)
  • Google map api (address analysis)
  • Firebase (log collect)
  • Snapchat share SDK (sharing to snapchat)
  • Tiktok share SDK (sharing to Tiktok)
  • Facebook share SDK (sharing to Facebook)
  • Agora (videos/ live stream)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot create an account
  • Cannot log you in
  • Cannot enjoy features available to registered users only
  • Cannot provide you with access to the App
  • Cannot allow you to make purchases
  • Cannot deliver the purchased items to you
  • Cannot process your payments
  • Cannot suggest products that you may be interested in

 

When you create an account, log in and use our App as a Creator


Specific personal data we collect

  • Full name
  • Email address
  • Shipping address
  • Billing address
  • Mobile phone number
  • Personal interests
  • Social media platforms accounts
  • Videos
  • Bank details
  • IMEII
  • phone model
  • local information from SDK card (access to storage, contacts list, camera and microphone on your phone, access to pictures & videos) and/or SIM card (country, network carrier, phone number)


Why is the personal data collected and for what purposes?

  • To allow you to post videos on the App
  • To send you products
  • To communicate with you
  • To pay you


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to provide you with access to and use of the App)


Third parties with whom we share your personal data

  • Rex Brown (logistic carrier, order fulfilment)
  • Stripe (Payment provider)
  • Trackingmore (shipping information tracking)
  • Ebanx (Brazil local Payment provider)
  • Avalara (tax solution)
  • Google pay/Apple pay (payment provider)
  • Payoneer (settlement)
  • Appsfly (users data analysis)
  • Google map api (address analysis)
  • Firebase (log collect)
  • Snapchat share SDK (sharing to snapchat)
  • Tiktok share SDK (sharing to Tiktok)
  • Facebook share SDK (sharing to Facebook)
  • Agora (videos/ live stream)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot allow you to post videos on the App
  • Cannot send you products
  • Cannot communicate with you
  • Cannot pay you

 

When you make use of, or interact with, our Mobile Web Pages for example, when you click through to purchase a product from social media channels or when you click through to the mobile web pages provided by a creator


When you create an account, log in and use our mobile web pages as a consumer


Specific personal data we collect

  • Full name
  • Email address
  • Shipping address
  • Billing address
  • Mobile phone number
  • Personal interests
  • phone model


Why is the personal data collected and for what purposes?

  • To be able to create an account
  • To be able to log in
  • To be able to enjoy features available to registered users only
  • To provide you with access to the App
  • To allow you to make purchases
  • To deliver the purchased items to you
  • To process your payments
  • To suggest products that you may be interested in


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to provide you with access to and use of the Mobile Web Pages)


Third parties with whom we share your personal data

  • Rex Brown (logistic carrier, order fulfilment)
  • Stripe (Payment provider)
  • Ebanx (Brazil local Payment provider)
  • Avalara (tax solution)
  • Google pay/Apple pay (payment provider)
  • Google map api (address analysis)
  • Agora (videos/ live stream)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot create an account
  • Cannot log you in
  • Cannot enjoy features available to registered users only
  • Cannot provide you with access to the mobile web pages
  • Cannot allow you to make purchases
  • Cannot deliver the purchased items to you
  • Cannot process your payments
  • Cannot suggest products that you may be interested in

 

When you provide us with your personal data for marketing reasons (e.g. when you attend a marketing event)


Specific personal data we collect

  • Full name
  • Job title
  • Email address
  • Company name
  • Phone number
  • Any other information that you provide us


Why is the personal data collected and for what purposes?

  • To establish a business connection
  • To send you marketing communications


Legal basis (GDPR only, if applicable)

Consent

Legitimate interest (e.g., to establish a business connection)


Third parties with whom we share your personal data

  • Payoneer (settlement)
  • Appsfly (users data analysis)
  • Firebase (log collect)
  • Snapchat share SDK (sharing to snapchat)
  • Tiktok share SDK (sharing to Tiktok)
  • Facebook share SDK (sharing to Facebook)
  • Agora (videos/ live stream)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot establish a business connection
  • Cannot send you marketing communications

When we use the personal data of our merchants / brands


Specific personal data we collect

  • Full name
  • Email address
  • Mobile phone number
  • Company name
  • Job role


Why is the personal data collected and for what purposes?

  • To contact our merchants / brands
  • To perform the applicable agreement
  • To send you marketing communications


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. Merchant Agreement)

Legitimate interest (e.g. perform the contract, send contract-related communications, to send you marketing communications)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot contact our merchants / brands
  • Cannot perform the applicable agreement

When we use the personal data of our service providers


Specific personal data we collect

  • Full name
  • Email address
  • Phone number
  • Company name
  • Any other information that you provide us


Why is the personal data collected and for what purposes?

  • To contact our service providers
  • To perform the applicable agreement


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract (e.g. services agreement)

Legitimate interest (e.g. perform the contract, send contract-related communications)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot communicate with you
  • Cannot perform the applicable agreement

 

When you interact with us on our social media profiles (e.g., Facebook, Instagram, Twitter, LinkedIn)


Specific personal data we collect

  • Full name
  • Email address
  • Social media channel
  • Any other data you decide to provide/supply


Why is the personal data collected and for what purposes?

  • To respond to your requests in our social media channels
  • To send you marketing communications


Legal basis (GDPR only, if applicable)

Legitimate interest (e.g. respond to your requests in our social media channels)

Consent (marketing)


Third parties with whom we share your personal data

  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • To respond to your requests in our social media channels
  • Cannot send you marketing communications

 

When you make use of, or interact with, our Mobile Web Pages


W
hen you get to our mobile web pages, create an account, log in and use our mobile web pages as a consumer


Specific personal data we collect

  • Full name
  • Email address
  • Shipping address
  • Billing address
  • Mobile phone number
  • Personal interests
  • phone model


Why is the personal data collected and for what purposes?

  • To be able to create an account
  • To be able to log in
  • To be able to enjoy features available to registered users only
  • To provide you with access to the App
  • To allow you to make purchases
  • To deliver the purchased items to you
  • To process your payments
  • To suggest products that you may be interested in


Legal basis (GDPR only, if applicable)

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to provide you with access to and use of the Mobile Web Pages)


Third parties with whom we share your personal data

  • Rex Brown (logistic carrier, order fulfilment)
  • Stripe (Payment provider)
  • Ebanx (Brazil local Payment provider)
  • Avalara (tax solution)
  • Google pay/Apple pay (payment provider)
  • Google map api (address analysis)
  • Agora (videos/ live stream)
  • Aliyun cloud (Data storage)
  • Tencent cloud (content storage)


Retention period

Until we no longer need the Information and proactively delete it or you send a valid deletion request. Please note that we may retain it for a longer or shorter period in accordance with data retention laws.


Consequences of not providing the personal data

  • Cannot create an account
  • Cannot log you in
  • Cannot enjoy features available to registered users only
  • Cannot provide you with access to the mobile web pages
  • Cannot allow you to make purchases
  • Cannot deliver the purchased items to you
  • Cannot process your payments
  • Cannot suggest products that you may be interested in

Finally, please note that some of the abovementioned personal data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

 

2. HOW WE PROTECT AND RETAIN YOUR INFORMATION

  • 2.1 – Security. We have implemented appropriate technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  • 2.2 – Retention of your personal data. In addition to the retention periods mentioned above, in some circumstances we may store your personal data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your personal data or dealings. We have an internal data retention policy to ensure that we do not retain your personal data perpetually. Regarding retention of cookies, you can read more in our cookie policy available at: com/cookies.

3. HOW WE SHARE YOUR PERSONAL DATA

 In addition to the recipients described above, we may share your personal data as follows:

  • 3.1 – With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
  • 3.2 – To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
  • 3.3 – If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events;
  • 3.4 – In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events; and/or
  • 3.5 – Where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).

4. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

    • 4.1 – External transfers: Where we transfer your personal data outside of EU/EEA (for example to third parties who provide us with services), we will obtain contractual commitments from them to protect your personal data in line with GDPR requirements.

 

5. YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT

  • 5.1 – Rights: The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR):
    • You have a right to access personal data held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
    • You have the right to request that we rectify any personal data we hold that is inaccurate or misleading;
    • You have the right to request the erasure/deletion of your personal data (e.g. from our records). Please note that there may be circumstances in which we are required to retain your personal data, for example for the establishment, exercise or defense of legal claims;
    • You have the right to object, to or to request restriction, of the processing;
    • You have the right to data portability. This means that you may have the right to receive your personal data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
    • You have the right to object to profiling;
    • You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
    • You also have a right to request certain details of the basis on which your personal data is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality;
    • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
  • 5.2 – You can exercise your rights by contacting us at privacy@ooooo.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
  • 5.3 – Deleting your account: Should you ever decide to delete your account, you may do so by emailing help@ooooo.com. If you terminate your account, any association between your account and personal data we store will no longer be accessible through your account. However, given the nature of sharing on certain services, any public activity on your account prior to deletion will remain stored on our servers and will remain accessible to the public.
  •  

                                                                             

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at help@ooooo.com.

 

7. INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

 

8. LOG FILES

We use log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users’ movement around the Website, and gather demographic information.

 

9. ANALYTIC TOOLS

  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personal information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  • Firebase Analytics. We also use “Google Analytics for Firebase”. By enabling this tool, we enable the collection of data about App Users, including via identifiers for mobile devices(including Android Advertising ID and Advertising Identifier for iOS), cookies and similar technologies. We use the information we get from Google Analytics for Firebase to maintain and improve our App(s). We do not facilitate the merging of personally-identifiable information with non-personally identifiable information unless we have robust notice of, and your prior affirmative (i.e., opt-in) consent to, that merger. Finally, please note that Google Analytics for Firebase’s terms (available at https://firebase.google.com/terms/) shall also apply.
  • AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform to understand the use of our services. AppsFlyer is exposed to the following data: (i) unique identifiers and technical data, such as IP address, User agent, IDFA (Identifier For Advertisers) or Android ID (in Android devices); and (ii) technical data regarding your operating system, device attributes and settings, applications, advertising opt-out signals, Google Advertiser ID, in-app events, device motion parameters and carrier. The use of this data allows us to analyze our campaigns and performance, as well as your habits and characteristics. For example, the data AppsFlyer receives includes downloads, impressions, clicks and installations of their mobile applications, mobile device use and data regarding in-app events. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.
  • Facebook Pixels and SDKs. We use Facebook pixels or SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Facebook, as such the collection and use of information for ad targeting. Please note that third parties, including Facebook, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Facebook’s ability to use and share information is governed by the Facebook Tools Terms (available at: https://www.facebook.com/legal/technology_terms/). You can prevent your data from being used by Facebook Pixels and SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • TikTok Share SDK. We use TikTok SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with Tiktok, as such the collection and use of information for ad targeting. Please note that third parties, including Tiktok, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. Tiktok’s ability to use and share information is governed by the Tiktok Terms of Service, (available at: https://www.tiktok.com/legal/terms-of-use?lang=en), and Privacy Policy (available at: https://www.tiktok.com/legal/privacy-policy?lang=en) . You can prevent your data from being used by Tiktok SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • SnapChat Share SDK. We use Snapchat SDKs, which are tools that provide help to website owners and publishers, developers, advertisers, business partners (and their customers) and others integrate, use and exchange information with SnapChat, as such the collection and use of information for ad targeting. Please note that third parties, including SnapChat, use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads. SnapChat’s ability to use and share information is governed by the SnapChat Terms of Service (available at: https://www.snap.com/en-US/terms/) and Privacy Policy(available at: https://www.snap.com/en-US/privacy/privacy-policy/) . You can prevent your data from being used by SnapChat SDKs by exercising your choice through these mechanisms: http://www.aboutads.info/ choices or http://www.youronlinechoices.eu/.
  • Advertising Partners.  Through our services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., your IP address, mobile/website identifiers, page(s) visited, location, time of day). We also combine and share such information and other information (such as demographic information and past purchase history) with third party advertising partners. These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know.

We reserve the right to remove or add new analytic tools.

 

10. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@ooooo.com.

  • Data controller: Video Commerce Group Ltd.

 

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