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.

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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.

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1. What we collect

Depending on which Services you use, we must process different kinds of

information from or about you.

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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.

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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.

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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.

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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.

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Third parties may also collect information about you through the Services, or

receive information collected about you through the Services, as described below.

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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.

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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

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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