Privacy Policy

 


PutView Privacy Policy


Last Updated: June 2, 2020



This Privacy Policy explains the information that PutView collects when you use its products and services, how that information is used, with whom it may be shared, and your privacy choices.



1. Introduction


Who we are and what we do

This Privacy Policy covers PutView, Inc. (collectively, “PutView,” “we” “us” or “our”). We provide online video hosting, sharing and related services through our owned-and-operated websites, including PutView.com, our branded applications for mobile and connected devices, and our embeddable video players (collectively, the “services”).


Acceptance and Changes

By registering for, downloading, or using our services, you accept this Privacy Policy, which is part of our Terms of Service. We may modify this Privacy Policy from time to time. 




2. Children's Privacy


We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old or the age of majority in your jurisdiction, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian's account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to PutView without your consent, you may ask us to delete such information by contacting us at [email protected].




3. Data We Collect About You


We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as "your data" for short.


Account Information

To create an account, you must provide a valid email address and password. If you choose to sign-up and/or authenticate using a third-party account (e.g., Facebook, Google), you authorize us to obtain account information from the third-party platform.


Financial Information

To make a purchase, you may need to provide a valid payment method (e.g., credit card or PayPal account). Your payment information will be collected and processed by our authorized payment vendors. We do not directly collect or store credit or debit card numbers ourselves in the ordinary course of processing transactions. If we allow purchase through a third-party platform (i.e. in-app purchase), the payment method stored with the third-party platform will be charged.


If you wish to sell items or earn money from advertising through our services, you must provide an account to receive funds and tax information, which may include your name, address, and taxpayer identification number.


Content

Accountholders may create a profile and upload content such as videos, text, photographs, and artwork. Your profile may display information about you and your activities. This information may be accessed by others. Your videos may be viewed and otherwise accessed by others, and associated metadata (e.g., titles, descriptions, tags, etc.) are viewable by others. Your interactions with other users (e.g., comments, "likes," private messages) may be seen by others. You may choose to limit the availability of your profile and videos. For more details, see Section 9.


If you submit images or videos to us in connection with our video creation and editing tools, we may analyze such content using a variety of techniques, including machine-learning algorithms, for the sole purpose of creating a video at your direction. In doing so, we may derive facial-related information from your content solely for the purpose of creating a video for you. This information may be used, for example, to locate a face within a frame. Facial landmarks are retained for 48 hours after a video editing session. We do not collect, use, or store any facial-related information for the purpose of recognizing faces outside of the limited video-creation purposes set forth herein.


Other Information You May Submit

You may submit data to us for limited purposes such as requesting customer support; answering a questionnaire; participating in a study; entering contests or sweepstakes; or signing up to receive communications from us or another user.


Automatically-Collected Information

We automatically collect certain types of data when you use our services, regardless of whether you have an account. This data includes your IP address, technical information about your device (e.g., browser type, operating system, basic device information), the web page you visited or search query you entered before reaching us, and your activities. We may track your activities using cookies and similar technologies. By using our services, you agree to our use of these methods as set forth in our Cookie Policy.


Physical Products

We collect your shipping address to send you products you have ordered.


Information Collected by Third Parties

Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).


We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.


 



4. How We Use Your Data


We may use your data for the following purposes:



  • Identification and authentication: We use your data to verify you when you access your account.

  • Operating our services: We use your data to provide our services, process and fulfill orders, provide customer support, and to otherwise comply with our contractual obligations to you. We (and/or our third-party vendors) use your financial information to process purchases made by you and to pay you amounts you have earned.

  • Communicating with you: We use your data when we communicate with you (e.g., when we respond to a customer support or other inquiry).

  • Improving our services: We use your data to understand how our services are being used and how we can improve them. In general, we analyze aggregated data, rather than specific user data. We may, however, need to analyze a specific case to address a specific problem (e.g., a bug that affects only a few accounts).

  • Customizing your experience: We use your data to personalize the service to you. This may include remembering your preferences for language or volume or displaying videos that you might enjoy, based upon your viewing choices.

  • Marketing and advertising: We use your data to show you ads on third-party sites and to send you offers. We may also use your data in delivering third-party advertisements to you. This may include "targeted ads" based upon your activities.

  • Exercising our rights: Where reasonably necessary, we use your data to exercise our legal rights and prevent abuse of our service. For example, we may use your data to detect and prevent fraud, spam, or content that violates our Terms of Service.

  • Legal compliance: We use your data where we are legally required to do so. For example, we may need to gather your data to respond to a subpoena or court order.

  • Protecting your information: Where appropriate, we may anonymize, backup, and delete certain data.


We may use algorithms and other automated means to implement any of the above.


Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:



  • Performance of a contract;

  • Legitimate commercial interest;

  • Compliance with a legal obligation; or

  • Consent


If you require further information about the balancing test that PutView has undertaken to justify its reliance on legitimate interest as a lawful basis of processing, see Section 15 for information on how to contact us.




5. With Whom We Share Your Data


We share data with third parties as follows:



  • As you instruct: We may make your profile and videos available to others as you instruct in using our services. We may share your data with persons to whom you have granted account-level access.

  • With your consent: We may share your data with third parties where we have obtained your express consent to do so.

  • Authorized vendors: We may share your data with third-party vendors that help us operate our services, process orders, and comply with your instructions and our contractual obligations. This includes payment processors, content delivery networks (CDNs), cloud-based hosting services, monitoring services, email service providers, quality assurance and testing vendors, fraud and abuse prevention vendors, customer relations management (CRM) vendors, and shipment vendors.

  • Advertising: We may share your data with advertising companies to display relevant ads to you.

  • Analytics: We may share your data with analytics providers which help us understand how customers are using our services.

  • Affiliates and advisors: We may share your data with our parent company, IAC/InterActiveCorp, and our auditors and advisors for planning, financial reporting, accounting, auditing, tax filings, and legal compliance. We may share your data with our affiliates to the extent necessary to provide you with the services ordered.

  • Certain legal situations: We may share your data where we believe disclosure is necessary to comply with a legal obligation or in connection with a corporate transaction as discussed in Section 6.

  • Aggregated or anonymized information: We may publicly disclose non-personal aggregated or anonymized information such as our number of visitors and registered users.


We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.




6. Legal and Safety-Related Disclosures


We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) ("requests") that we receive from government authorities or parties to legal proceedings. We direct law enforcement agencies to our Law Enforcement Guidelines page.


We handle U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.


We may disclose user data where we reasonably believe that someone's life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person's data with appropriate entities that may have the ability to help.


We may disclose user data to report suspected crimes. We report content suspected of exploiting minors to the National Center for Missing and Exploited Children (NCMEC) along with the data identifying the uploading user.


We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.


We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.


 



7. Data Retention


We retain your data for as long as you have an account. When you close an account, we will delete its content, including its videos. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.


We retain deleted videos on our servers for a short period in case you wish to reverse deletion. Once we delete a video, we may not be able to recover it. If you have previously made a video public, the video or its thumbnail may be discoverable in a search engine's cache for a time. We have no control over search engines; however, we will, upon request, send a request for deletion to major search engines.


If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.






8. Your Privacy Choices


We enable you to make numerous choices about your data:



  • You may choose not to provide us with certain information. For example, you may choose not to create an account or not to provide optional account information.

  • You may change your account and video privacy settings. See Section 9 for more details.

  • You may change or correct information voluntarily submitted to us. We encourage you to keep your data current by viewing your settings page.

  • You may opt out of receiving commercial emails from us. See Section 10 for more details.

  • You may limit the use of cookies. See our Cookie Policy for options.

  • You may backup your videos.

  • You may close your account (which will delete all videos) or delete certain videos.


Users in certain jurisdictions may have additional rights. See Section 14 for more details.




9. Account and Video Privacy Settings


As part of our services we offer you the ability to limit the distribution of your content, including your videos. This section explains some of your choices.


Profile

Some of our online subscription plans enable you to "hide" your profile or otherwise make it inaccessible on our website. Your profile will, however, remain accessible to persons who have access to your account or content.


 


Videos

We enable you to manage the privacy settings of your videos. On PutView.com, for example, your options, which depend on your subscription plan, may include:



  • Public (or "anyone"): Your video will be publicly-available.

  • Private (i.e., "only me"): Your video will be available to you and authorized Team Members.

  • Unlisted: Your video may be accessed by anyone who enters the link assigned to it.


Changes will be applied on a go-forward basis. You should exercise caution in granting access to others. Once you have granted access to someone else, you lose a degree of control over the distribution of your video as those persons may share the password and/or link with other people. Regardless of your profile or video privacy settings, PutView reserves the right to inspect them for compliance with its Terms of Service, to provide customer support, or to address technical issues.




10. Communications from Us


Emails

If you create an account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).


Mobile Device Communications

We may, with your consent, send push notifications in our apps. You may disable these by declining them or changing the app's settings. To the extent provided, we may, with your consent, send SMS messages to your mobile telephone for authentication and security purposes. You may opt out of receiving such messages at any time.



11. Protecting Your Information


We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.




12. Your Responsibilities


You may receive other people's data in using our service. If you receive information from other users, you must comply with all laws, including those concerning privacy, data security, and online marketing.




13. Third-Party Services


We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. For example, if you click on an advertisement, you may be taken to the advertiser's website. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.


You may use our service through third-party sites. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps and video players, but does not cover any third-party site or any third-party video player.





14. International Data Transfers and Certain User Rights


PutView is based in the Australia. We provide services globally using computer systems, servers, and databases located in the U.S. and other countries. When you use our services from outside of the U.S., your information may be transferred to and processed in the U.S.. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country.


 


15. How to Contact Us


For any questions, inquiries, or complaints relating to your privacy, please contact us at: [email protected]