VIEWERSLOGIC LTD. (“VL” or “we”) respects your privacy. This privacy policy (the “Privacy Policy”) explains our collection, use and disclosure practices in connection with the information we collect from users of our proprietary mobile application (the “App”) and associated services (collectively, the “Services”), as well as the rights and options available to you with respect to such information.
The term “personal data”, as used in this Policy, means information relating to an identified or identifiable natural person. This Privacy Policy incorporates by reference the most current version of our terms of use which are available at https://docs.viewerslogic.com/docs/TOS-latest.html ("Terms of Use"). If you have questions or complaints regarding this Privacy Policy and/or our privacy practices in general, please contact us as described in this Privacy Policy.
We may change this Privacy Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularly visit and review this Privacy Policy to stay informed of such practices. IF YOU DO NOT WISH THAT WE WILL COLLECT INFORMATION ABOUT YOU (i.e., YOUR PERSONAL DATA) IN CONNECTION WITH YOUR USE OF THE SERVICES AS DESCRIBED ABOVE, PLEASE DELETE THE APP AND REFRAIN FROM USING THE SERVICES.

Personal Data that VL collects

In the course of registering for, and using the App, we will require you to provide personal data. If you do not enter the requisite data in the mandatory fields, you will not be able complete the relevant registration form. It’s important that you understand there is no requirement by law for you to provide VL with your personal details – the information you share with us is entirely voluntary.
The Services also allow us to gather information about your mobile usage and TV-viewing activities, preferences, behavior, communications and interactions and to gather information regarding the TV channels you watch, the websites and apps that you visit, and the information for which you searched and viewed via our Services.
We request that you provide VL with complete, accurate and correct details. Your failure to do so will likely result in VL being unable to contact you about your inquiries into our Services.
If, at some point, you request the removal of your personal data from our Services, VL will undertake reasonable efforts to accommodate your request, but it may not always be possible to do so. If that should happen, we’ll notify you accordingly.

Information gathered when using the Services

VL collects various kinds of information pertaining to your use of our Services. Additionally, VL may collect or use the assistance of third parties to collect and analyse anonymous, statistical or aggregative information related to your use of our Services, including information related to your personal details and activities. More specifically, VL collects the following:

Personal Data: We collect personal data about when you establish an account (bearing a unique log-in and password), and for billing/payment purposes.
General Device Information: We collect information about your device type, i.e., address., Wi-Fi networks signals strength, battery level, time zone, network status, browser type, browser identifier, unique device identification number, and any other information that alone or in combination may be used to uniquely identify your device.
TV Watching: We collect information about your TV watching patterns and preferences, including but not limited to, whether your TV is on or off, the TV channels you are watching, the time you watch each channel, ID of the TV and type of the TV, volume of TV, PVR viewing, VOD viewing etc.
Online & Device Activities: We may collect data about the identity of the websites you visit, browsing history, the search terms you use and their results, apps used, apps installed, calls times and duration etc.
Geographic Location: We may collect information regarding the location of your device (i.e., by requesting your permission to obtain geo-location data from your device and/or by obtaining geo-location information through Wi-Fi networks you are logged to). The geo-location information may be provided by the Services at any time, whether the App is open or not.

Legal Basis for Processing

VL will only process and use personal data relating to you where VL have a legal basis to do so. We rely on one or more of the following legal bases:

We rely on consent where we have obtained your active agreement to use personal data relating to you for a specified purpose. You have the right to withdraw your consent at any time.

Performance of a contract with you when we provide and maintain our Services. When we process your account information, and technical information solely to provide our Services to you, this information is necessary to be able to perform our contract with you and to provide our Services. If you do not provide this information, we may not be able to provide our Services to you.
Compliance with our legal obligations when we process personal data relating to you to comply with applicable law. We will identify the relevant legal obligation when we rely on this legal basis.
Legitimate interests: We may use personal data relating to you where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. This may include the processing of account information and technical information. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use personal data relating to you for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Joint Controllership

Currently, VL does not jointly determine the purposes and means of processing the App personal data with any third-party (a “Joint Controller”). If a Joint Controller situation is established in regard to your personal data, the essence of the legal arrangement between VL and such other controller shall be made available to you upon request.

How We Use Personal Data Relating to You

We will store the personal data you provide and the information we collect about your activity via the Services throughout our databases. We reserve the right to use such information for the following purposes:

To provide the Services and to enable you to use them;
To improve and expand the Services;
To improve and customize your experience and other users' experience with our Services;
To contact you occasionally, either by VL or by a third party acting on our behalf, regarding VL’s Services and/or products. We will only send you such direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
To contact you as and when VL believes it to be necessary for technical, administrative or security reasons;
To analyze traffic of users and visitors and identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them;
To improve the delivery of services to the user. This includes customer support and troubleshooting, process and usability improvements, performance analysis.

We will process, use, retain and share personal data solely for the purposes described in this Privacy Policy and only when reasonably necessary and proportionate to achieve such purposes for which such information was collected and processed.

To the extent relevant and possible, we will make efforts to maintain the personal data accurate, complete and up to date.

How and With Whom Personal Data Is Shared

The categories of third parties with whom we share Personal Data are described below.

A. Sharing with third parties to provide our Services

Service Providers. To assist us in meeting business operations needs and to perform certain services and functions, we provide Personal Data to vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software, and web analytics services, among others (“Service Providers”). Pursuant to our instructions, these parties will access, process, or store Personal Data only in the course of performing their duties to us.
Academic Institutions. We share personal data relating to you with academic institutions for the purpose of conducting scientific research activities, for example in the field of marketing research or social studies. Such personal data is pseudonymized and we will not share your name or contact information.
Business Partners. We share personal data with VL’s business partners for the purpose of such partners’ market research. Such personal data is pseudonymized and we will not share your name or contact information.
We share personal data relating to you with third parties that may also have personal data / information about you, so that both VL and such third parties may jointly develop applications, offerings or services that will deliver a more customized user experience.

B. Sharing With Third Parties to Protect Us or Others

We will disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. In addition, we will disclose or use users' personal data to defend or enforce our legal rights and in accordance with any applicable law.

In any case where VL reasonably believes that sharing personal data relating to you is necessary to prevent serious damage to your person or property or to the person or property of any third party;

C. Disclosure in the Event of Merger, Sale, or Other Structural Change

In the event that we, or a part of our business, are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider (together, a “Structural Change”), we will transfer Personal Data relating to you as part of the Structural Change, provided that the receiving entity will comply with this policy.

Cross-Border Data Transfers

Although the Services are only offered by VL in the United Kingdom, we transfer personal data outside of the United Kingdom to countries that have been recognized as providing an adequate level of protection for personal data.

In such cases, we ensure that appropriate safeguards are in place to protect your personal data in accordance with applicable data protection laws. You can request further information about these safeguards by contacting us at privacy@viewerslogic.com.

When we transfer personal data to any of our service providers or partners in a third country, we ensure that there is a lawful basis for the transfer (such as an adequacy decision, Standard Contractual Clauses as adopted by the European Commission, or a certification under the UK Extension to the EU-U.S. DPF), in order to safeguard the transfer of personal data we collect and to ensure that adequate protection for personal data relating to you is provided as required by applicable law.

Access to Third Party Apps & Solutions

Our Services may enable you to access other applications and solutions that are not owned or controlled by VL (the “Third Party Solutions”). Please be aware that we do not control and are not responsible for the privacy practices of such Third Party Solutions. We encourage you to read the privacy statements of each and every one of the Third Party Solutions that you use.

Data Security

We take steps to ensure that personal data is treated securely and in accordance with this Privacy Policy. We have put in place appropriate implements data security systems and procedures to safeguard and secure personal data related to you from loss, misuse, unauthorized access or disclosure, alternation or destruction. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security. Therefore, VL cannot guarantee or warrant that the Services or our website will be immune from cyber-attacks, malicious activities, malfunctions, honest mistakes or other types of abuse and misuse. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

Personal Data Retention and Deletion

We will only retain personal data relating to you for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain personal data relating to you for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of personal data relating to you, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see the section titled “Your Legal Rights” below for further information.
We will keep aggregated or anonymized information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable Personal Data, when we no longer need to process the information.
In any case, as long as you use the Services, we will keep information about you, unless applicable law requires us to delete it.

Your Legal Rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Note also that in the event that you ask us to erase your account information, any remaining points associated with your account will be lost.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide the Services to you. We will advise you if this is the case at the time you withdraw your consent.
You are entitled to request to restrict access to personal data related to you in limited circumstances as described under the UK GDPR, subject to certain exceptions.
You have a right to lodge a complaint with the Information Commissioner's Office (ICO) with regard to an alleged infringement of the UK GDPR.

If you wish to exercise any of the rights set out above, please contact us by sending an email to privacy@viewerslogic.com or by mail to: ViewersLogic Group PLC., 1 Hallswelle Road, London NW11 0DH.

We will undertake to respond to your request within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Before VL is able to provide you with any information or correct any inaccuracies, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

Children’s Online Privacy Information

VL does not knowingly collect personal information from minors who are under the age of 16 through the Services without appropriate consent. If a parent or guardian becomes aware that his or her child has provided us with personal data without his/her consent, then he or she should contact VL at the information described below. If VL becomes aware that a child under the age of 16 has provided it with personal data, VL will delete such information from our records.

Changes to this Privacy Policy

From time to time, VL may change the terms of this Privacy Policy. Changes will take effect once they are posted online. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.

Inquiries or Concerns?

Should you have any questions or concerns regarding this Privacy Policy, you may contact VL. You can reach him/her by sending an email to privacy@viewerslogic.com. We will do our best to provide a prompt response to your questions/concerns.