Exclusivi Limited

Exclusivi Privacy Policy

Effective Date: July 1st 2016

Exclusivi Limited (“we”, “us”, “our”) are committed to protecting and respecting your privacy.

  1. SCOPE OF POLICY

1.1.     This policy (together with our terms of use are set out at www.exclusivi.com/privacypolicy and any additional terms incorporated by reference into our Terms of Use (together our “Terms of Use”)) applies to your use of:

1.1.1.     certain software program(s) that are proprietary to us and which are provided in object code form on customised android TV set top boxes which provide smart TV functionality to existing television sets that have high-definition multimedia interfaces (the “Set Top Boxes”), (herein referred to as the “Exclusivi Platform”) and any related application(s) (the “App”) (together the “Services”); and

1.1.2.     any of the services accessible through the Services.

1.2.     This policy sets out the basis on which any data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your data and how we will treat it.

1.3.     For the purpose of the Data Protection Directive 95/46/EC, we are the data controller.

1.4.     By using the Services you are accepting and consenting to the practices described in this policy.

  1. INFORMATION WE MAY COLLECT FROM YOU

2.1.     We may collect and process the following data about you:

2.1.1.     Information you give us (“Submitted information”)

You may give us information about you by filling in forms on the Services or by corresponding with us (for example by e-mail). This includes information you provide when you use the Services, register to use the Services, make a purchase as result of your use of the Services and when you report a problem with the Services. The information you give us may include your name, address, e-mail address, phone number, date of birth, gender, contact number(s), occupation, financial and credit card information, and related information, other registration information and any other personal information you may give to us.

2.1.2.     Information we collect about you (“Collected Information”)

Each time you use the Services we may automatically collect the following information:

2.1.2.1.   technical information, including without limitation the internet protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

2.1.2.2.   information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;

2.1.2.3.   details of your use of the Services (including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise) and the resources that you access;

2.1.2.4.   some of the Services may require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by emailin support@exclusivi.com; and/or

2.1.2.5.   if you contact us, we may keep a record of that correspondence.

2.1.3.     Information we receive from other sources (“Third Party Information”)

We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and we may receive information about you from them.

  1. WHEN WE SHARE PERSONAL INFORMATION

3.1.     We may disclose some or all of the data in the following circumstances:

3.1.1.     With your consent

We will only share personal information with companies, organisations or individuals when we have your consent to do so.

3.1.2.     Affiliates, vendors, and agents

We provide personal information to affiliates or other trusted businesses or persons to process it for us or to act on our behalf. These parties are subject to contracts and confidentiality agreements and have no independent rights to use data outside of what this privacy policy allows.

3.2.     We may disclose your personal information to advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.

3.3.     We use analytics service providers and search engine providers in order to better understand usage patterns of the Services and to assist us in the improvement and optimisation of the Services. These providers collect information on our behalf using cookies and similar technologies. We do not engage in “tracking” users outside of our Services.

3.4.     We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

3.5.     We may disclose your personal information to persons utilising the Services who you are not connected with.

3.6.     We may disclose your personal information to third parties:

3.6.1.    in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

3.6.2.    if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets;

3.6.3.    if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request; or

3.6.4.    in order to:

3.6.4.1.   enforce or apply our Terms of Use and other agreements or to investigate potential breaches; or

3.6.4.2.   protect our rights, property or safety and that of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

 

  1. USES MADE OF THE INFORMATION

4.1.     We use information held about you in the following ways:

4.1.1.     Submitted Information may be used in the following circumstances:

4.1.1.1.   to carry out the Services and our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;

4.1.1.2.   to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;

4.1.1.3.   to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing user, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those you have previously used. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;

4.1.1.4.   to respond to inquiries, where in such circumstances, we may keep a record of your communication to help solve any issues you might be facing;

4.1.1.5.   to notify you about changes to our Services; and

4.1.1.6.   to ensure that content from our Services is presented in the most effective manner for you.

4.1.2.     Collected Information may be used in the following circumstances:

4.1.2.1.   to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

4.1.2.2.   to improve our Services to ensure that content is presented in the most effective manner for you and for your computer;

4.1.2.3.   to allow you to participate in interactive features of the Services, when you choose to do so;

4.1.2.4.   as part of our efforts to keep our Services safe and secure;

4.1.2.5.   to measure or understand the effectiveness of advertising we serve to you and others and to deliver relevant advertising to you; and

4.1.2.6.   to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.

4.1.3.     Third Party Information may be used in the following circumstances:

We may combine Third Party Information with the Submitted Information and the Collected Information and we may use this combined information for the purposes set out above (depending on the types of information we receive).

4.1.4.     We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

  1. WHERE WE STORE YOUR PERSONAL DATA

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It may also be processed by staff that operate outside the EEA and who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

 

  1. SECURITY

6.1.     We take reasonable measures to protect your personal information in an effort to prevent loss, misuse and unauthorised access, disclosure, alteration, and destruction. We take the following steps to help keep personal information secure:

6.1.1.     we encrypt data transmissions using SSL technology;

6.1.2.     we have reasonable measures in place to protect the physical security of records we store on our premises;

6.1.3.     we restrict access to personal information to employees, contractors, agents and other trusted business partners who need to know that information in order to process it for us for the purposes described above, and who are subject to confidentiality or employment agreements; and

6.1.4.     we take steps to ensure that adequate levels of data protection are provided in any country outside of the EEA to or in which we may transfer or maintain your personal information.

6.2.     Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to the Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Access to any of your personal data is restricted to only those of our employees who are authorised to access such personal data and only on terms in compliance with this privacy policy. All employees are given proper instruction on the handling of any personal data.

  1. YOUR RIGHTS

7.1.     You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at support@exclusivi.com.

7.2.     The Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the Apps or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

  1. ACCESS TO INFORMATION

The Data Protection Directive 95/46/EC gives you the right to access information held about you. Your right of access can be exercised in accordance with that Directive. Any access request may be subject to a fee to meet our costs in providing you with details of the information we hold about you.

  1. THIRD PARTY MATERIAL

We accept no liability howsoever arising for the content, accuracy or reliability of any third party materials or websites, or any part of them, which may be referenced from time to time by link or other means at this site or for the data collection and use practices or security measures exercised by third parties.

  1. CHANGES TO PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next log onto the Services. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Services.

  1. CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to support@exclusivi.com or Exclusivi Ltd, No. 1 Grants Row, Lower Mount Str., Dublin 2.