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PRIVACY POLICY (2019/05/19)
General Privacy Policy for Videolayer (MEMRY AB)
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Videolayer is committed to ensuring that your privacy is protected. Should we ask
you to provide certain information by which you can be identified when using our
websites, our services or our products (below we use the word "Services" for
easier review), you can be assured that it will only be used in accordance with
this Privacy Policy.
​
This Privacy Policy outlines how Videolayer generally handles your personal data.
In connection with some of our Services, we will give you more specific
information about our handling of your personal data, and we will, where
appropriate, ask for your consent before handling your personal data. At the end
of this policy, there is information on how to contact us if you have any questions
or if you think anything is unclear.
​
​
1. What we collect
Depending on which Services you use, we must process different kinds of
information from or about you.
​
Here's how:
Personal data and other information you (and others) give us.
We collect the information that you (and others) give us when using our Services.
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For example:
When you register to use our Services, we may ask for information such as your
name, email address and phone number.
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For many of our Services, you will have the opportunity to create a user profile
(for example in one of our web-based Services), and add information to your
profile after registration.
​
If you buy something from us, we collect information about the transaction. This
can include your payment information, purchase activity and delivery and contact
details.
​
When you communicate with Videolayer, you provide us with information such as
your email address and phone number.
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We collect content and information about content that you create using our
Services.
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Personal data and other information which is automatically collected about you
when you use our services.
​
We also collect information automatically when you are connected to our
Services. Depending on how you access and use our Services, we collect
information such as:
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Information about how you access our Services, including information about the
type of product & service that you're using, its configuration (such as your
operating system), your browser, and how your product & service is performing.
Information about the features you interact with on our Services. For example,
when you use our devices, we may collect information on how often you use a
certain feature, including from third parties.
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Information about you and your social media profile if you choose to access our
Services with a social media profile. Please note that the information you share
within the scope of those social media services, is not applicable to this Privacy
policy.
​
Third parties may also collect information about you through the Services, or
receive information collected about you through the Services, as described below.
​
Related companies
We may share your personal data within the Videolayer Group (MEMRY AB) in
order to develop and improve our products and Services. Such information,
however, is anonymized to the best extent possible.
​
Third party companies
Some of our Services offers the opportunity to use a social media account as an
access method to the Service. If you choose to do so, that social media platform
will receive information that you chose that access method at one of Videolayer’s
Services, and we will receive some types of information from the social media
site. How that social media platform processes your information falls outside the
scope of this Privacy policy.
​
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2. How do we use your personal data?
We use the information as set out below and to provide our Services to you and
our partners.
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Here's how:
To provide and personalize our Services.
We use the information we collect to provide you with our Services. For example,
we use this information to:
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Provide you with software, content, apps and other needs;
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Create accounts and user profiles;
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Communicate with you about our Services;
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Provide technical support;
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Notify you about updates to our Services; and
Customize your usage based on your activities, including the content, apps and
other experiences you interact with. This allows us to make our Services unique
and relevant to you, for example by showing you content that is most relevant to
you.
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To improve and develop your experience and our Services.
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We also use the information that we collect to understand, develop and improve
our Services. For example, we use the information to:
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Seek and analyse input and feedback about our Services;
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Identify and address technical issues on our Services;
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Conduct and learn from research about the ways in which people use our
Services; and
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Improve services offered by others, such as third parties that offer apps and other
content connected to our Services.
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To promote our brand and Services
We use the information that we collect to send you promotional messages and
content and otherwise market to you on and offer our Services. We also use this
information to measure how users respond to our marketing efforts. If you would
like to opt out of receiving marketing emails, then you can always do so by follow
the instructions implemented in every such promotional message.
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To promote safety and security
We use the personal data that we collect to help promote safety and security on
and off our Services, such as by investigating suspicious activity or breaches of
our terms or policies and protecting our or others’ rights or property.
​
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3. How is personal data shared?
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To provide and support our Services, information that we have about you is
shared in certain circumstances. The following can see information about you
when you and others use our Services.
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Developers, support and other online content providers on our services.
You can interact with Third-party content, apps and other experiences through
our Services. We may share information about you with these partners so they
can provide you with the experiences that you've requested, such as:
Information in your Videolayer profile and about how you use our Services. For
example, we may provide a third-party video provider with your user id or similar,
so that the video provider may deliver a video to you that’s similar to other
videos you’ve seen in the Videolayer services.
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Any other information that you choose to share with the third party through your
use of the Services.
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Sharing within related companies. Depending on which services you use, we
share information with companies that are part of the same group of companies
that Videolayer is part of, or that become part of that group.
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Service providers
We share the information that we collect with vendors, service providers,
researchers and other partners, who work at our direction to support the Services
(such as hosting our Services, fulfilling orders, facilitating payments, analysing
the way people use our Services, processing credit card payments, providing
customer service or sending electronic communications for us).
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Other parties in connection with certain business transactions
In the event that the ownership of Videolayer (or any portion of our assets)
changes as a result of a merger, acquisition or in the event of a bankruptcy,
information from or about you or your device may be transferred to another
company.
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Law enforcement or legal requests
We share information with law enforcement or in response to legal requests in the
circumstances outlined in Section 7 below.
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We also share de-identified or aggregate data with others. “De-identified data”
means information where we have removed identifiable data such as your name
and other data that could reasonably be used to identify you. “Aggregate data” is
data that has been combined with other data so that it doesn't identify any
specific person. For example, we provide developers with aggregated statistics
about the number of people from a particular region that use our Services, so
developers can create content tailored for people in that market.
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4. How the Videolayer companies work together
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Videolayer shares infrastructure, systems, and technology with other Videolayer
companies (MEMRY AB) to provide an innovative, relevant, consistent and safe
experience across all Services that you use.
​
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5. Third parties that provide content, marketing or functionality
on our services
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Some of the content, marketing and functionality on our Services may be
provided by third parties that are not affiliated with us. For example, we work
with companies that help us provide content within the Service that you
purchased.
​
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6. Data retention and deletion
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We store data that identifies you until it is no longer necessary to provide our
Services, for example when you delete an account with us. This is a case-by-case
determination that depends on things such as the nature of the data, why it is
collected and processed, and relevant legal or operational retention needs. For
example, we may retain certain purchase information for accounting and tax
purposes even after you have deleted your account.
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When you delete an account with us, we delete or anonymize the data you
provided us with and the data we collected during your use of the Services.
Neither you nor us will be able to restore such deleted or anonymised data.
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7. How do we respond to legal requests and minimize harm?
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We access, preserve and share information with regulators, law enforcement or
others:
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In response to a legal request where we have a good faith belief that the
response is required by law in that jurisdiction, affects users in that jurisdiction
and is consistent with internationally recognized standards.
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When we have a good faith belief that it is necessary to: detect, prevent and
address fraud or other illegal activity; to protect Videolayer, our Services, you and
others, including as part of investigations; or to prevent death or imminent bodily
harm.
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8. How we operate and transfer data as part of our global services
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We share information globally, both internally within the Videolayer Group
(MEMRY AB) and externally with our partners to fully provide the Services you are
entitled to receive based on the Service you have purchased or subscribed to
and/or otherwise are entitled to receive. Information controlled by Videolayer will
be transferred or transmitted to, or stored and processed in the United States,
China and/or other countries outside of where you live for the purposes as
described in this policy. These data transfers are necessary for us to globally
operate and provide our Services to you. We utilize standard contract clauses
approved by the European Commission and rely on the European Commission's
adequacy decisions about certain countries, as applicable, for data transfers from
the EU/EEA to the United States and other countries.
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9. Changes to this policy
​
If we make changes to this Privacy Policy, we will provide notice of such changes
as appropriate, such as by sending you an email notification to the address that
you've provided, and/or providing notice through the Services. If we make an
administrative change, we may update the "Last Updated" date at the top of this
Privacy Policy.
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The Data Protection Officer for Videolayer (MEMRY AB) can be contacted at
dpo@videolayer.com. You also have the right to lodge a complaint with the
Swedish lead supervisory authority, the Datainspektionen,
www.datainspektionen.se
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10. What is our legal basis for processing data?
The legal ground for processing personal data varies depending on the types of
data and the situation. The legal grounds we rely on at Videolayer are the
following:
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If processing is necessary to fulfill our contract with you, i.e. what we are obliged
to provide under the agreement between you and us. Our obligations to you vary
depending on the Service you are using.
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As necessary to comply with our legal obligations; for example, Videolayer must
store some purchase information to comply with tax and accounting regulations.
The legal ground for this processing (storing) is therefore necessary for
compliance with legal obligations.
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As necessary for our (or others) legitimate interests. Videolayer has a legitimate
interest in providing an innovative, personalized, safe and profitable service to
our existing and future users and partners, unless those interests are overridden
by your interests or fundamental rights and freedoms that require protection of
personal data.
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11. How can you exercise the rights provided to you under the GDPR?
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Under the General Data Protection Regulation, you have the right to:
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Access your data
You have the right to obtain from Videolayer a confirmation of whether or not
personal data concerning you is being processed, and if that is the case, a right
to access information including, but not limited to, the purpose of the processing
and the categories of personal data that Videolayer has concerning you. By your
request, Videolayer is required to provide you with a copy of undergoing
processing of your personal data.
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Rectify your data
If it comes to your knowledge that certain personal data of yours which is being
processed by Videolayer is inaccurate, you have the right to obtain a rectification
and in some cases a right to have incomplete data completed.
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Port your data
If the legal ground for a processing of personal data is based on either (i) consent
or (ii) fulfilment of a contract between you and Videolayer, you have a right to
receive data which you have provided us in a commonly used and machine-
readable format and have the right to transmit such data to another controller.
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Erase your data
You have the right to obtain from Videolayer the erasure of your personal data
when, for example, (i) the data no longer is necessary in relation to the purpose
for which it was collected, (ii) if you withdraw a consent, (iii) if you object to the
processing and there are no overriding legitimate grounds for the processing, or if
(iv) the personal data have been unlawfully processed.
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Restrict and object to certain processing of your data
You have the right to restrict Videolayer from processing your data when, for
example, (i) you contest the accuracy of the personal data, or (ii) if Videolayer no
longer needs certain data for the purposes of the processing.
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Find out more about these rights, and how you can exercise them by either
contacting Videolayer at dpo@videolayer.com or obtain information from the
appropriate supervisory authority.
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12. Contacting us
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The data controller responsible for your information is Videolayer which you can
contact by e-mail at dpo@videolayer.com or by post at:
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Att: Data Protection Officer
Videolayer / MEMRY AB
Vastmannagatan 24
113 60 Stockholm
Sweden
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