Privacy Policy

1. Important information and who we are

Purpose of this privacy policy

This policy is intended to explain how Vidione collects and uses personal data through your use of the Applications and our services. This may include information you provide through the Applications, for example when you use our support tools on our website, create an account, buy a service, or upload and edit audio or video files.

The Applications are not intended for children, and we do not knowingly collect information relating to children.

You should read this policy together with any other privacy notice or fair-processing notice we provide when collecting or using personal data. Those notices give additional information about how and why your data is used and supplement this policy rather than replace it.

Controller

Vidione Limited, referred to in this policy as “Vidione”, “we”, “us”, or “our”, is the controller responsible for your personal data unless we process it because you use our services through a relationship with a customer to whom we provide services, such as an employer or another organisation.

We have appointed a data privacy manager to oversee questions relating to this policy. If you have questions or want to exercise your legal rights, please contact the data privacy manager using the details below.

Where we process personal data because you use our services through a relationship with one of our customers, we act as that customer’s data processor rather than as the controller.

In that situation, you should refer to the relevant customer’s privacy policy. The customer’s policy should explain how your personal data is processed.

Contact details

If you have questions about this policy or our privacy practices, please contact our data privacy manager using the following details:

Full legal entity name: Vidione Limited
Email address: [email protected]
Postal address: 17–18 Clere Street, Shoreditch, London EC2A 4LJ

You may also complain to the Information Commissioner’s Office (ICO), the UK regulator for data protection matters. We would appreciate the opportunity to address your concerns first, so please contact us before approaching the ICO where possible.

Changes to the privacy policy and your duty to inform us of changes

We review this policy regularly. You can request earlier versions by contacting us.

It is important that the personal data we hold about you is accurate and current. Please tell us if your personal data changes during your relationship with us.

Third-party links

The Applications may contain links to third-party websites, plug-ins, and applications. Following those links or enabling those connections may allow third parties to collect or share information about you. We do not control those websites and are not responsible for their privacy statements. When you leave the Applications, we encourage you to read the privacy policy of every website you visit.

2. The personal data we collect about you

Personal data, or personal information, means information about an individual from which that person can be identified. It does not include data from which identity has been permanently removed, such as anonymous data.

We may collect, use, store, and transfer different categories of personal data. We group them as follows:

• Identity Data includes first name, former or middle names, last name, username or similar identifier, marital status, title, date of birth, gender, and visual or audio identifiers where you appear in content uploaded to the Applications.

• Contact Data includes billing address, email address, telephone number, and similar contact details.

• Financial Data includes bank account information and payment card details.

• Transaction Data includes details of payments made to or received from you and information about services you have purchased from us.

• Technical Data includes your internet protocol address, login information, browser type and version, time-zone setting, approximate location, browser plug-in types and versions, operating system and platform, other technology used to access the Applications, and information contained in or associated with audio or video you provide, such as its creation date or location metadata.

• Profile Data includes your username and password, purchases or orders, interests, preferences, feedback, and survey responses.

• Usage Data includes information about how you use the Applications and services.

• Marketing and Communications Data includes your preferences for receiving marketing from us and our partners, together with your communication preferences.

We may also collect, use, and share Aggregated Data, such as statistical or demographic information, for any purpose. Aggregated Data may come from personal data but is not treated as personal data in law when it cannot directly or indirectly identify you. For example, we may combine Usage Data to calculate the percentage of users who access a particular feature. If we combine Aggregated Data with personal data so that you could be identified, we treat the combined information as personal data under this policy.

We do not ask you to provide Special Categories of Personal Data, including information about race or ethnic origin, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade-union membership, health, genetic information, or biometric information. We also do not ask for information about criminal convictions or offences.

You may choose to provide Special Categories of Personal Data by uploading video, audio, or other information to the Applications. If you provide that information about yourself, you give us explicit consent to process it to the extent permitted by applicable UK or EU data-protection law. If you provide this kind of information about someone else, you must first obtain their explicit written consent for us to process it. We may ask you to provide evidence of that consent. You must not upload content containing Special Categories of Personal Data about another person unless you have obtained the required consent.

Special Categories of Personal Data receive additional protection under applicable UK and EU data-protection regimes.

If you fail to provide personal data

Where we need personal data by law or under a contract with you and you do not provide it when requested, we may be unable to perform the contract we have or are trying to enter into with you, such as providing a service. We may then need to cancel the relevant service, and we will tell you if that happens.

3. How is your personal data collected?

We use several methods to collect information from and about you, including the following:

• Direct interactions. You may give us Identity, Contact, and Financial Data by completing forms or corresponding with us by post, telephone, email, or another method. This includes information you provide when you:

  • apply for our services;

  • upload audio or video files to the Applications;

  • create an account in the Applications;

  • subscribe to a service or publication;

  • ask for marketing to be sent to you;

  • complete a survey;

  • send feedback or contact us; or

  • take part in a programme, forum, or group that we invite you to join.

• Automated technologies or interactions. As you use the Applications, we may automatically collect Technical Data about your equipment, browsing activity, and patterns of use. We collect this information through cookies, server logs, and comparable technologies. We may also receive Technical Data when you visit other websites that use our cookies. Please see our cookie policy for further information.

• Third parties or publicly available sources. We may receive personal data about you from third parties and public sources, including:

  • Technical Data from:

    • analytics providers;

    • advertising networks; and

    • search-information providers.

  • Contact, Financial, and Transaction Data from technical and payment-service providers.

  • Identity and Contact Data from data brokers or aggregators.

  • Identity and Contact Data from publicly available sources, such as company registers and electoral registers where available.

4. How we use your personal data

We use personal data only when the law allows us to. Most often, this will be in the following circumstances:

• We need it to perform a contract we are about to enter into or have entered into with you.

• It is necessary for our legitimate interests, or those of a third party, and those interests are not overridden by your interests or fundamental rights.

• We need it to comply with a legal obligation.

The lawful bases we rely on are explained in the Glossary.

Generally, consent is not our legal basis for processing personal data, except where it is required for Special Categories of Personal Data or for certain automated decisions. We will obtain your consent before sending third-party direct marketing by email or text message. You may withdraw consent to marketing at any time by contacting us. We do not sell your personal data to third parties.

Purposes for which we will use your personal data

The table below describes the ways we plan to use personal data and the lawful bases on which we rely. It also identifies our legitimate interests where relevant.

We may process your personal data on more than one lawful basis depending on the particular purpose. Please contact us if you need more detail about the legal basis used for a specific activity.

Marketing

We may use Identity, Contact, Technical, Usage, and Profile Data to understand what you may need or find interesting. This helps us decide which services and offers could be relevant to you; we refer to this as marketing.

You may receive marketing communications from us if you asked for information or purchased from us and have not opted out of marketing.

Third-party marketing

We will obtain your express consent before sharing your personal data with another organisation for that organisation’s own marketing purposes.

Opting out

You may ask us or third parties to stop sending marketing messages at any time by using an opt-out link in a marketing message, where available, or by contacting us.

Opting out of marketing does not affect personal data provided to us as part of a service purchase, service experience, or other transaction.

Cookies

You can configure your browser to reject all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of the Applications may become inaccessible or may not work correctly. More information is available in our Cookie Policy.

Change of purpose

We will normally use your personal data only for the purposes for which we collected it. We may use it for another purpose where we reasonably consider that the new purpose is compatible with the original one. Contact us if you would like an explanation of that compatibility.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that permits us to do so.

We may process personal data without your knowledge or consent where this is required or permitted by law and is consistent with the rules described above.

Automated decision-making

Automated decisions are made through technology, usually using algorithms and predefined criteria. Decisions made solely by technological means, without human intervention, may have legal or similarly significant effects on you.

By using the Applications or our services, you give us explicit consent to make automated decisions where consent is required. If you do not consent to those decisions, you must not use the relevant Applications or services.

The Applications may use personal data in decisions that are wholly or partly automated for the purposes described in this policy. Automated processing may be used where necessary to enter into or perform a contract with you, or where the law allows it on the basis of consent.

The reasons for automated decision-making may include:

• suggesting settings or tips when you use our services;

• enabling or improving the decision-making process;

• providing fair and consistent treatment using uniform criteria;

• reducing possible harm caused by human error or personal bias that could result in unfair treatment or imbalance; or

• reducing the risk that you fail to meet an obligation under your contract with us.

Your rights as a result of automated decision-making

Where you are subject to automated decision-making, you may exercise specific rights intended to prevent or limit the possible effects of those decisions.

In particular, you may:

• ask for an explanation of a decision made through automated processing and express your view about it;

• challenge the decision by asking us to reconsider it or make a new decision on another basis; or

• request and obtain human intervention in the processing.

Contact us if you want more information about the purposes, third-party services, or specific reasoning involved in automated decisions used within the Applications.

Push notifications and email notifications

The Applications may send push notifications, and we may send email notifications, to achieve the purposes described in this policy.

In most cases, you can stop push notifications through your device settings, including the notification settings for mobile phones. Disabling push notifications may affect your experience of the Applications.

Except where email notifications are necessary for purposes listed in the table above, you can usually opt out by contacting us, selecting the “Unsubscribe” option at the end of an email, or changing your communication preferences in the Applications.

5. Disclosures of your personal data

We may share personal data with the parties listed below for the purposes described in the table under “Purposes for which we will use your personal data”.

• Third parties described in the Glossary.

• Third parties to whom we may sell, transfer, or merge parts of our business or assets. We may also acquire another business or merge with one. If our business changes hands, the new owners may use personal data in the way described in this policy.

We require all third parties to protect the security of your personal data and to process it in accordance with the law. Our service providers may not use your personal data for their own purposes and may process it only for specified purposes and in accordance with our instructions.

6. International transfers

Some external service providers are based outside the UK or the European Economic Area (“EEA”). Their work may therefore involve transferring personal data outside the UK or EEA.

Whenever we transfer personal data outside the UK or EEA, we provide a similar level of protection by ensuring that at least one of the following safeguards applies:

• We transfer personal data only to countries recognised by the UK or the European Commission as providing an adequate level of protection, where applicable.

• When a country does not have an adequacy decision, we ensure that an appropriate legal basis and, where required, a recognised safeguard is in place so that the data is handled consistently with applicable data-protection laws and regulations.

• For certain service providers, we may use approved contractual arrangements that provide personal data with protection equivalent to that available in the UK or EEA, where applicable.

Contact us if you want more information about the specific mechanism used for a particular transfer.

7. Data security

We use appropriate security measures to help prevent personal data from being accidentally lost, used, accessed, changed, or disclosed without authorisation. Access is limited to employees, agents, contractors, and other third parties who have a business need to know. They may process personal data only on our instructions and are subject to confidentiality obligations.

We also maintain procedures for dealing with suspected personal-data breaches and will notify you and any applicable regulator when the law requires us to do so.

8. Data retention

How long will you use my personal data for?

We retain personal data only for as long as reasonably necessary to fulfil the purposes for which it was collected, including legal, regulatory, tax, accounting, and reporting requirements. We may retain it for longer where there is a complaint or where we reasonably believe litigation may arise in relation to our relationship with you.

When deciding how long to retain personal data, we consider the amount, nature, and sensitivity of the information; the risk of harm from unauthorised use or disclosure; the purposes for which we process it; whether those purposes can be achieved by other means; and applicable legal, regulatory, tax, accounting, or other requirements.

You may request details of the retention periods that apply to different types of personal data by contacting us.

In some circumstances, you may ask us to delete your data. See the “Your legal rights” section below for more information.

Where we use universally unique identifiers (“UUID”) for analytics or to remember your preferences, a UUID is generated when you install a programme. It remains in place between launches and updates but is lost when you delete the programme. A new UUID is generated if you reinstall it.

In some circumstances, we anonymise personal data so that it can no longer be associated with you. We may then use the anonymised information indefinitely for research or statistical purposes without further notice.

If you are or were a free-tier user and request deletion of personal data used for Development and Improvement Processing, for example after deleting your account or moving to a paid subscription, we will delete that personal data where there is no other valid reason to keep it, such as a legal requirement. We may continue using information derived from that processing if it has been deidentified, anonymised, or aggregated so that it no longer identifies you, your content, or another person.

9. Your legal rights

In certain circumstances, data-protection law gives you rights in relation to your personal data.

Broadly, you may have the right to:

• Request access to your personal data, commonly known as a data-subject access request. This allows you to receive a copy of the personal data we hold about you and check that we are processing it lawfully.

• Request correction of personal data we hold about you. This lets you ask us to correct incomplete or inaccurate information, although we may need to verify the accuracy of the new information you provide.

• Request erasure of your personal data. You may ask us to delete or remove it where there is no good reason for us to continue processing it. You may also ask us to delete data where you have successfully objected to processing, where it has been processed unlawfully, or where local law requires erasure. We may be unable to comply for specific legal reasons, which we will explain when relevant.

• Object to processing where we rely on a legitimate interest, including a legitimate interest of a third party, and something about your situation makes you want to object because you believe processing affects your fundamental rights and freedoms. You may also object where we process personal data for direct marketing. In some cases, we may demonstrate compelling legitimate grounds that override your rights and freedoms.

• Request restriction of processing of your personal data. You may ask us to suspend processing in the following situations:

  • you want us to establish the accuracy of the data;

  • our use of the data is unlawful but you do not want us to erase it;

  • we no longer need the data, but you need us to retain it to establish, exercise, or defend legal claims; or

  • you have objected to our use of the data and we need to verify whether we have overriding legitimate grounds to use it.

• Request transfer of your personal data to you or another party. We will provide the information you gave us in a structured, commonly used, machine-readable format where this right applies. It generally applies only to automated information that you initially provided to us with your consent or for performance of a contract.

• Withdraw consent at any time where we rely on consent to process your personal data. Withdrawal does not affect the lawfulness of processing carried out before you withdrew consent. If withdrawing consent means we can no longer provide a service, we will explain this when you withdraw it.

If you want to exercise any of these rights, please contact us.

If you are or were a free-tier user and want to object to or opt out of Development and Improvement Processing involving personal data contained in content uploaded under your free subscription, you may do so at any time. If you object during that subscription, you cannot continue using the Applications on the free tier and must either delete your account or move to a paid subscription.

No fee usually required

You normally do not have to pay a fee to access your personal data or exercise your other rights. We may charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive. We may also refuse to comply in those circumstances.

What we may need from you

We may ask for specific information to help confirm your identity and establish your right to access personal data or exercise another right. This security measure helps prevent information being disclosed to someone who has no right to receive it. We may also contact you for further information to help us respond more quickly.

Time limit to respond

We aim to respond to legitimate requests within one month. A request may take longer where it is particularly complex or where you have made several requests. If that happens, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing operations so that we can provide a good, secure, and useful experience. Before relying on this basis, we consider and balance any potential impact on you, whether positive or negative, against your rights. We do not use personal data for activities where our interests are overridden by the effect on you, unless we have your consent or the law otherwise requires or permits the activity. Contact us if you want more information about how we assess legitimate interests for a particular activity.

Performance of Contract means processing personal data where it is necessary to perform a contract to which you are a party or to take steps at your request before entering into a contract.

Comply with a legal obligation means processing personal data where it is necessary for compliance with a legal obligation to which we are subject.

THIRD PARTIES

The current list of service providers, subcontractors and sub-processors we use is available on request from [email protected].

Personal information collected from connected third-party accounts

Vidione may collect and store certain information when you connect your Vidione account to an external account or service. Please read the privacy policy of the connected service and the terms that apply to creating the connection.

If you disconnect a connected third-party account, Vidione will delete the stored data associated with that account. You may also be able to revoke access through the third-party account itself.

For example, if you connect Vidione to a video-channel service, we may access information about your channel through that service’s API. This may include a channel image, title, account identifier, email address, live broadcasts, access tokens, and information about live videos such as viewer counts, comments, or stream names.

If you connect an external video channel to your Vidione account, you should read that provider’s privacy policy. You may also be able to revoke access through the provider’s security or account-permissions settings.

Connected services and terms

If you connect Vidione to an external account, you may also be bound by that provider’s terms of service. Please review the applicable terms before creating or maintaining the connection.