Privacy Policy

Last updated: 23.07.21

TheViewPoint Media Inc. is committed to respecting and protecting the privacy of personal information of identifiable individuals. This Privacy Policy explains how we (“TheViewPoint”, “we”, “us” or “our”) collect, use, protect, disclose personal information of individuals who visit the website (the “Site”) and use the services available or offered thereon (the “Services”).

We respect your privacy and are committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.

If you do not agree with our policies and practices, do not use the Site. With, accessing, or using the Site, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of or access to the Site after we make changes is deemed to be acceptance of those changes, so please check this page periodically for updates.

OUR PRINCIPLES REGARDING PRIVACY AND DATA PROTECTION

Lawfulness, transparency and fairness;
Purpose Limitation;
Data Minimization;
Accuracy;
Storage limitation;
Confidentiality and integrity.

Your privacy and security are of the utmost importance to us. We will always follow these principles.

WHAT INFORMATION DO WE COLLECT AND PROCESS

We collect information from and about users of the Site:

Directly from you when you provide it to us;

Automatically when you use the Site (some information – such as IP address and/or browser and device characteristics); and

Data we collect from our partners.

DATA WE COLLECT FOR OUR ANALYTICS

Device info including the device model and IP address;
UI activity events (e.g. clicked on active buttons/ elements of the Site): information about your interactions with the Site such as your search queries (including the date and time of any requests you make).
Inferences drawn about your interests and preferences based on your usage of the Site:
Certain technical data, which may include:
URL information;
online identifiers including cookie data and IP addresses;
information about the types of devices you are using such as unique device IDs, network and device performance, browser type, language, information enabling digital rights management, operating system;
your non-precise location, which may be derived or inferred from certain technical data (e.g., your IP address, language setting of your device).

INFORMATION YOU PROVIDE TO US

When you are filling out forms via the Site, we may ask you to provide information (a) by which you may be personally identified, such as name, company name, email address, or any other personal or personally identifiable information under applicable law (“personal information“), and/or (b) that is about you but individually does not identify you.

This information includes:

Information that you provide by filling in forms on the Site. This includes information provided at the time of registering to use or access the Site. We may also ask you for information when you interact with us (such as when responding to notices and announcements from us) or otherwise correspond with us.
Records and copies of your correspondence (including email addresses), if you contact us;
Your responses to surveys that we might ask you to complete for research purposes.

INFORMATION COLLECTED AUTOMATICALLY

While using our Site, we may collect certain personally identifiable information that can be used to contact or identify you which also includes: IP Address, Cookies, Usage Data. This personal information is necessary to manage our Site, communicate with you about the Site, and for other purposes set out in this Privacy Policy.

You voluntarily consent to the collection, use and disclosure of such personal information by providing personal information to us and by continuing to use the Site. Without limiting the aforesaid, if appropriate, you may be asked to provide your consent when we collect, use, or disclose your personal information in particular circumstances. Take into account, occasionally, your consent will be implicit through your conduct with us in the case the purpose of the collection, use or disclosure is clear and voluntarily provided by you.

COOKIES, INFORMATION COLLECTION AND TRACKING TECHNOLOGIES

We may use cookies and log files to track user information. Cookies are small amounts of data that are transferred to your web browser by a web server and are stored on your computer’s hard drive. We use cookies to track which page variant a visitor has seen, to track if a visitor has clicked on a page variant, to monitor traffic patterns and to assess popularity of services options. We will use this information to deliver relevant content and services to you. This also allows us to make sure that visitors see the landing page they expect to see if they return to the same web URL and it allows us to tell you how many people click on your landing pages. You can disable cookies in your settings, but some parts of the Site may then not function properly. Specific information about how we use Cookies and how you can refuse certain cookies is set TheViewPoint Cookie Policy. You can refuse certain cookies here.

Web Beacons. Parts of the Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Site statistics (for example, recording the popularity of certain Site content, features, functionality, and services, and verifying system and server integrity).

Some information – such as IP address and/or browser and device characteristics – is collected automatically when you visit our websites.

We automatically collect certain information when you visit, use or navigate the Site. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Site and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

Additionally, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.

Note: that certain cookies are necessary to enable the website to operate and refusing or disabling some or all cookies may limit your ability to make use of the Site.

AGGREGATED DATA

From time to time we may use your personal information to generate Aggregated Data for internal use and for sharing with others on a selective basis. “Aggregated Data” means records which have been stripped of information potentially identifying customers, landing pages or end-users, and which have been manipulated or combined to provide generalized, anonymous information. Note: that any such aggregated data will not include any personal information, and we will never make it available to third parties to use for their own purposes.

DISCLOSURE OF YOUR PERSONAL DATA

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

Furthermore, we do not share, distribute, sell, trade, rent or otherwise transfer to outside parties your personally identifiable information without first receiving your permission or as permitted in this Privacy Policy. We will only share your information with third parties in accordance with your instructions or as necessary to provide you with a specific service or to trusted third parties who assist us in operating our Site, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

Under certain circumstances, TheViewPoint may be required to disclose your personal information if required to do so by law, or in response to valid requests by public authorities (e.g. a court or a government agency).

The following personal data will only be shared with the categories of recipients outlined in the table below if:

you choose to make use of a specific Site feature where sharing of particular personal data is required for the proper use of the Site feature; or
you grant us your permission to share the personal data, e.g. by selecting the appropriate setting in the Services or authorizing TheViewPoint through a presented consent mechanism.

In addition, we may disclose personal information that we collect or you provide:

In addition, we may disclose personal information for the following categories of recipients and for the following reasons:

Service providers	We work with service providers that work on our behalf which may need access to certain personal data in order to provide their services to us. These companies include those we’ve hired to provide customer service support, operate the technical infrastructure that we need to provide the Services, assist in protecting and securing our systems and services, and help market own products and services as well as partner products, services, events, and co-branded promotions in which we involved. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity
Advertising partners	We work with advertising partners to enable us to customize the advertising content you may receive on our Services. These partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising), contextual advertising, and generic advertising on the Site. We and our advertising partners may process certain personal data to help TheViewPoint understand your interests or preferences so that we can deliver advertisements that are more relevant to you.
Our partners	Depending on how you access the Site (e.g. through a third-party service or a mobile provider), we may share your information as necessary. We may also share personal data with that third party about your use of the Site.
Affiliates	We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us
Law enforcement and data protection authorities	We may share your personal data when we in good faith believe it is necessary for us to do so in order to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena. We also may share your personal data where we in good faith believe that it is necessary for the purpose of our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, provided that we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Business Transfers	We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TheViewPoint our customers, users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

HOW DO WE USE YOUR INFORMATION

TheViewPoint uses the collected data for the following purposes:

to provide and maintain the Site and Services;
to provide information that may improve the Site and Services;
to notify you about changes or additions to our Services;
to compile aggregate data about Site traffic and Site interaction so that we can offer better Services;
to assess services levels, Site traffic and popularity of different services options;
to provide customer support;
to carry out our marketing activities;
to enforce this Privacy Policy;
to respond to claims of any violation of our rights or those of any third parties;
to protect the rights, property or personal safety of you, our visitors, other users and our business;
and may use personal information for other purposes for which we have a legitimate interest or as required or authorized by law;
to send you marketing and promotional communications (for Business Purposes and/or with your Consent). We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out marketing via dpo@theviewpoint.com emails at any time;
to send administrative information to you (for business purposes, legal reasons and/or possibly contractual). We may use your personal information to send you product, services and new feature information and/or information about changes to our terms, conditions, and policies;
to deliver targeted advertising to you (for our Business Purposes and/or with your Consent). We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness;
to protect our Site (for Business Purposes and/or Legal Reasons). We may use your information as part of our efforts to keep our Site safe and secure (for example, for fraud monitoring and prevention);
to send you related information, such as updates, security alerts, and support messages;
in all of the above cases and purposes, we may analyze, profile, and segment all collected data, including for the purpose of estimating our audience size and usage patterns.

We may periodically communicate with you via email address you provide for us regarding to your transactions, orders, our products, services, updates, news, events, etc. We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails or you can communicate with us and tell us not to communicate this information to you. We will process your request within a reasonable time after receipt.

Note: that you will continue to receive transaction-related emails regarding the Site you have requested, including information specific to your account, planned Services suspensions and outages, updates to our Terms or this Policy. We will attempt to minimize this type of communication to you.

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

HOW DO WE PROTECT YOUR INFORMATION

We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process which included:

using secure shell protocol (SSH);
multi-factor authentication;
access control (physical and technical);
link encryption.

The protection of your personal information is important to us. We maintain appropriate safeguards and current security standards to protect your personal information from unauthorized access, disclosure, or misuse, such as using Secure Socket Layer (SSL) encryption for all supplied sensitive/credit information. However, no system can be completely secure, and we cannot ensure or warrant the security of any information you provide to us. While we take meaningful steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure. We do not accept liability for unintentional disclosure.

However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

We are not responsible for the safety of any information that you share with third-party providers who advertise, but are not affiliated with, our websites.

The Site may contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

Personal information will be pseudonymised and encrypted to ensure the user privacy. The collected information will be handled for standard cases of use described in this Privacy Policy.

THIRD PARTY LINKS

Our Site may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

DATA WE COLLECT FROM OUR PARTNERS

We also collect the following data from our partners:

location data (such as to determine the coarse location of your IP address);
data for analytics purposes, so we can provide you with better services.

We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.

THIRD-PARTIES

When you use or access Site or its/their content, certain third parties may use automatic information collection technologies to collect information about you or your device, or you may otherwise be accessing and using third-party platforms, software, and applications.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about a third party’s processing of your information, you should contact the responsible provider directly. You acknowledge and agree that your access and use of such third party tools may be subject to their respective terms of use and privacy policies.

We may also partner with selected third-party vendors (subprocessors) to allow tracking technologies and remarketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors.

Full list of third-party you can find here: “Disclosure of Your Personal Data“.

DATA TRANSFERS AND INTERNATIONAL DATA TRANSFERS

We only share information with your consent, to comply with laws, to protect your rights, or to fulfill business obligations.

We only share and disclose your information in the following situations:

Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer services and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you. See our Cookie Policy for further information.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
With your Consent. We may disclose your personal information for any other purpose with your consent.

Our servers are located in the USA. If you are accessing our Site from outside the USA, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in other countries. In such instances TheViewPoint shall ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

TheViewPoint, the Site, and the services are global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than the United States (or your own country, if you are using the Site outside the United States, despite the geographic restrictions provided in the Terms), we take steps to ensure adequate safeguards are in place to protect your data as explained in this privacy policy.

Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission.

When we transfer personal data from the European Economic Area to other countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your data.

Such measures implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between us and our third-party providers, which require all such recipients to protect personal information that they process from the EEA in accordance with European data protection laws. Our Standard Contractual Clauses are available here. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

AGE OF CONSENT

We do not knowingly collect, maintain, or use personal information from individuals under the age of consent (18 years of age). If you have reason to believe that anyone under the age of consent has provided us with personal information, you may contact us immediately. If we become aware that we have collected any personal information from individuals under the age of consent we will promptly take steps to remove and permanently delete such information.

YOUR RIGHTS AND OPTIONS

You have the right to opt-out of marketing emails and other direct marketing (if any);

Access the personal data we hold about you. If you request, we will provide you a copy of your personal data in an electronic format; and

You also have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can withdraw your consent, for example by turning off cookies in your browser settings. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please let us know. You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

All these rights may be fulfilled by you simply emailing us with the relevant request to dpo@theviewpoint.com

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use our Data Protection Officer – dpo@theviewpoint.com. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.

WHAT DATA PROTECTION RIGHTS YOU HAVE UNDER GENERAL DATA PROTECTION REGULATION (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TheViewPoint aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your personal information.

The General Data Protection Regulation or “GDPR” gives certain rights to individuals in relation to their personal data. Accordingly, we are happy to offer transparency and access controls to help users take advantage of those rights. As available and except as limited under applicable law, the rights afforded to individuals are:

Right of access – the right to be informed of, and request access to, the personal data we process about you;
Right to rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
Right to erasure – the right to request that we delete your personal data;
Right to restrict – the right to request that we temporarily or permanently stop processing all or some of your personal data;
Right to object – the right, at any time, to object to us processing your personal data on grounds relating to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
Right to data portability – the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service; and
Right not to be subject to automated decision-making – the right to not be subject to a decision based solely on automated decision-making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

We will process your requests to us within 30 days. We will also notify a relevant supervisory authority within 72 hours from a breach related to your personal information that we hold.

Furthermore, we have assigned a Data Protection Officer (DPO) who may be reached via dpo@theviewpoint.com

However you can also contact and have the right to lodge a complaint with your local Data Protection Authority.

Additional privacy rights under the California Consumer Privacy Act (CCPA) can be found in California Online Privacy Protection Act Compliance section, which contains supplemental disclosures relating to the processing of your personal data.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT COMPLIANCE

The California Code of Regulations defines a “resident” as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

Beginning January 1, 2020, the California Consumer Privacy Act (“CCPA”) gives California residents certain rights with respect to the processing of personal data (known as “personal information” under the CCPA).

This supplement provides additional privacy disclosures and details additional rights and should be read in conjunction with our Privacy Policy.

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under Disclosure of Your Personal Data section.

If you are a California resident and would like to make such a request, please submit your request in writing to us via dpo@theviewpoint.com

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Personal Information Collected and Processed

Requests to Exercise Your Rights

Disclosures of Personal Information for a Business Purpose

Sale of Personal Information

Personal Information Collected and Processed

Our Privacy Policy sets forth the categories of personal information that We collect and processes about you, a description of each category, and the sources from which we obtain each category.

Requests to Exercise Your Rights

RIGHT TO KNOW REQUEST – Under the CCPA, you have a right to request information about our collection, use, and disclosure of your personal information over the prior 12 months, and ask that we provide you with the following information:

Categories of and specific pieces of personal information we have collected about you;
Categories of sources from which we collect personal information;
Purposes for collecting personal information;
Categories of third parties with which we share personal information;
Categories of personal information disclosed about you for a business purpose.

If applicable, categories of personal information sold about you and the categories of third parties to which the personal information was sold, by category or categories of personal information for each third party to which the personal information was sold.

To make a verifiable request for information about the personal information we have collected about you, please to make a request by using the dpo@theviewpoint.com

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

RIGHT TO DELETE REQUEST – You also have a right to request that we delete personal information, subject to certain exceptions. You may exercise your right to delete emailing to dpo@theviewpoint.com.

HOUSEHOLD REQUESTS – We currently do not collect household data. If all the members of a household make a Right to Know or Right to Delete request, we will respond as if the requests are individual requests.

REQUESTS, GENERALLY – Please note, if you have not filled our Site’s forms we will not have enough information about you to verify your Right to Know and Right to Delete requests, as we do not keep sufficient information necessary to reidentify and link you to a prior visit to the user services where data may have been collected. As such, we will be unable to verify and honor your requests. You may make a verifiable consumer request related to your personal information twice per 12-month period. We will not discriminate against you for exercising any of your rights under the CCPA.

REQUESTS MADE THROUGH AGENTS – You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Disclosures of Personal Information for a Business Purpose

In the preceding 12 months, We have disclosed certain data from the following categories of personal information to the categories of recipients listed in Section “Disclosure of Your Personal Data” of our Privacy Policy for one or more business purposes:

None

Sale of Personal Information

We do not sell personal information. We have taken substantial steps to identify and remediate any data sharing arrangements that could constitute a “sale” under the CCPA.

While we do not sell any personal information, we do provide Usage Data to advertising partners to enable us to provide you with interest-based advertising. For more information on interest-based advertising, please see our Cookies Policy.

We will continue to update our business practices as regulatory guidance becomes available and provides clarity on what constitutes a sale transaction, particularly in the advertising ecosystem.

To exercise these rights, you can contact us by email at dpo@theviewpoint.com. If you have a complaint about how we handle your data, we would like to hear from you.

EU-U.S. PRIVACY SHIELD STATEMENT

TheViewPoint Media Inc. (“we,” “us,” “our”) complies with the EU-U.S. Privacy Shield Framework Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom to the United States in reliance on Privacy Shield. TheViewPoint Media Inc. has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this privacy policy and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks,TheViewPoint Media Inc.is subject to theinvestigatoryand enforcement powers of the U.S. Federal Trade Commission.

We have adopted and subscribed to the EU-U.S. Privacy Shield Framework and the Privacy Shield Framework (collectively, “Privacy Shield”) as part of our efforts to establish and maintain an adequate level of Personal Data privacy protection. We adhere to the Privacy Shield Principles including the Supplemental Principles, (collectively, the “Privacy Shield Principles”) for Personal Data received from entities in the European Economic Area (the “EEA”), the United Kingdom (“UK”).

In addition to the measures provided for by the Privacy Shield we provide adequate safeguards that which in particular include Standard Contractual Clauses approved by EU Commission.

When we receive personal data from the European Economic Area or transfer personal data from the European Economic Area to other countries, we use appropriate legal mechanisms to help ensure all applicable laws, rights and regulations continue to protect your data.

Also, the transfer of personal data is carried out using the protective measures mentioned in the section “How Do We Protect Your Information”.

Our commitments under this policy apply to the processing of Personal Data that TheViewPoint Media Inc. obtains from Customers located in the European Union.

Pursuant to the Privacy Shield Frameworks, EU, UK individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States.Upon request, we will provide you with access to the personal information that we hold about you.You may also correct, amend, or delete the personal information we hold about you.An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query dpo@theviewpoint.com or info@theviewpoint.com.If requested to remove data, we will respond within a reasonable timeframe.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized.To request to limit the use and disclosure of your personal information, please submit a written request todpo@theviewpoint.com or info@theviewpoint.com.

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

TheViewPoint Media Inc.’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles.In particular,TheViewPoint Media Inc.remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with thePrinciples, unlessTheViewPoint Media Inc.proves that it is not responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, TheViewPoint Media Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union, United Kingdom individuals with Privacy Shield inquiries or complaints should first contact TheViewPoint Media Inc. at: dpo@theviewpoint.com or info@theviewpoint.com.

TheViewPoint Media Inc. has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, TheViewPoint Media Inc. is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

As a last resort and in limited circumstances, EU individuals with unresolved privacy complaints may invoke a binding arbitration option before a Privacy Shield Panel.

DO NOT TRACK NOTICE

We don’t currently respond to Do Not Track and similar signals. Please go to All About Do Not Track for more information or use this page.

CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

In the event of a change of ownership or other business transition, such as a merger, acquisition or sale of our assets, your information may be transferred in accordance with applicable privacy laws.

DATA RETENTION

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements).

Note that if you ask us to remove your personal data, we may retain your data as necessary to comply with our legal obligations.

We process and for about 6 months store the pseudonymized data on the cloud servers with all necessary means and measures of data protection, let alone special requirement provided by GDPR (fraud, legal claim, etc.). Other than that, all personal data is deleted once the 6-month period is over.

If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless we are legally allowed or required to maintain certain personal data, including situations such as the following:

Where we need to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

THEVIEWPOINT AS DATA PROCESSOR

TheViewPoint`s customers, and not TheViewPoint, may determine the purpose and means of processing Personal Data provided to TheViewPoint by or at the direction of such customers (“Data Controllers”). In such event TheViewPoint (“Data Processor”) is a “data processor” under the EU General Data Protection Regulation (“GDPR”) and a “service provider” under the California Consumer Privacy Act (“CCPA”). TheViewPoint performs such processing services on behalf of its customers in accordance with this Privacy Policy and/or the terms of the agreement between TheViewPoint and the particular customer. To the extent that TheViewPoint’s agreement with a customer conflicts with the terms of this Privacy Policy, the terms of such agreement will govern.

As Data Controllers, TheViewPoint’s customers are responsible for disclosing the rights of individuals with respect to their Personal Data, and terms for the collection and use of that Personal Data, in accordance with the GDPR, CCPA, and other laws requiring such disclosures.

TheViewPoint’s customers (not TheViewPoint), determine the purpose and means of processing Personal Data of EU persons provided to TheViewPoint as a Data Processor by or at the direction of such customers. TheViewPoint performs such processing in accordance with this Privacy Policy and the terms of data processing agreements executed by TheViewPoint with such customers. TheViewPoint customers are responsible for disclosing the rights and terms for processing of Personal Data in accordance with the EU General Data Protection Regulation.

CHANGES TO THE POLICY

This Policy may be updated by us from time to time. Amendments to this Privacy Policy will be posted to the Site and/or Services and will be effective when posted. Your continued use of the Services following the posting of any amendment to the Privacy Policy shall constitute your acceptance of such amendment.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.

TERMS OF SERVICE

Please also visit our Terms of Use which state the terms, disclaimers, and limitations of liability governing your use of the Site and Services.

YOUR CONSENT

By using our Site, you consent to our Privacy Policy.

CONTACT US

If you have any questions or suggestions regarding our Privacy Policy, please contact us at info@theviewpoint.com

If you have any requests for resolving issues (other than issues related to data protection) we encourage you to contact us through dpo@theviewpoint.com or info@theviewpoint.com

If you are a resident in the European Economic Area, the “data controller” of your personal information is TheViewPoint Media Inc., with the address at 79 Madison Ave, New York City, New York 10016, USA.

In the case described in TheViewPoint as data processor, the “data controller” of your personal information are TheViewPoint`s customers.