Last Updated: June 2020
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 analyze 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:
Legal Basis for Processing
VL will only process your personal data on its own behalf where VL have a legal basis to do so. Although the overwhelming majority of users of the Services will expressly consent VL’s processing of their personal data, the following are other the legal basis which may be applicable from time to time:
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.
Use of Personal Data and other Information
We will store the personal data you provide and the information we collect about your activity via the Services throughout our databases (the "Databases"). We reserve the right to use such information for the following purposes:
Transfer of Personal Data to Third Parties
In addition to the foregoing, VL is entitled to transfer or share anonymous, statistic or aggregative information with companies or organizations connected to VL, and with suppliers, business partners, advertisers, and every third party, according to VL’s absolute discretion; however, VL will not disclose your identity to them, knowingly or deliberately, without receiving your consent.
Data Transfers and Global Processing
Although the Services are only offered by VL in the United Kingdom, your personal data may be accessed and/or processed from and/or transferred to other countries beyond the UK. We may do this where data is accessed/processed:
By consenting to the collection and use of your personal data, you agree to your personal data being transferred and stored in this manner and for the specified purposes. Additionally, the safeguards we deploy for performing such transfers across boundaries include:
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 files.
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 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, whether or not such service collects personally identifiable information. This privacy statement applies only to information collected via VL’s Services.
VL implements data security systems and procedures to secure the information stored on VL’s systems. Such systems and procedures reduce the risk of security breaches, but they do not provide absolute security. Therefore, VL cannot guarantee that the Services are immune to unauthorized access to the information stored therein and to other information security risks.
Access to Personal Data
If your personal data changes, or if you no longer desire to use and access our Services, you may correct, update, delete/deactivate your information by emailing VL via the contact information listed below. We will undertake to respond to your request within 30 days of VL’s receipt thereof. Although VL will make reasonable efforts to accommodate your requests, in some circumstances we may not agree. If that should happen, VL expressly reserves the right to refuse your request to change the personal data in VL’s records, and will instead append an alternative text to the record in question. 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.
You may have the rights prescribed below in relation to personal data processed by us if you are a data subject in the European Economic Area or your personal data is otherwise governed by the GDPR:
You may exercise these rights to the extent these rights apply to you by contacting VL via the contact information listed below. We will undertake to respond to your request within the applicable time frame prescribed by applicable law, and in any event we will make efforts to respond within 30 days of receipt of your request. Although VL will make reasonable efforts to accommodate your requests, in some circumstances we may deem your request unfounded or not eligible under applicable law. If that should happen, VL expressly reserves the right to refuse your request personal data. Before VL is able to accommodate any request, provide you with any information or correct any inaccuracies VL reserves the right to verify your identity by requesting certain information or identification. If you should elect to withdraw your consent for processing of your personal data, VL reserves the right to discontinue your right to use the Services (and by extension, will cease any remittances of monies towards your use of the Services and VL’s right to process your personal data in connection therewith).
Inquiries or Concerns?
1. What is a cookie?
A cookie is a small text file that is stored in your web browser that allows VL or a third party to recognize you. Cookies might be used for the following purposes: (1) to enable certain functions; (2) to provide analytics; and (3) to store your preferences.
Cookies can either be session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years. Cookies placed by the website you’re visiting are sometimes called “first party cookies,” while cookies placed by other companies are sometimes called “third party cookies.”
2. What cookies are used when I use the Services?
When you access and/or use our Services, we or a third party may place a number of cookies in your device browser. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.
Each cookie serves one of four different purposes:
Finally, we may set cookies within emails we send to you (if you have consented to receiving emails from us). These cookies are used to track how often our emails are opened and clicked on by our customers. You can manage email cookies in the same way as website cookies, as explained above.
4. What are my cookie options?
If you don’t like the idea of cookies or certain types of cookies, you can change your browser’s settings to delete cookies that have already been set and to not accept new cookies. To learn more about how to do this, visit the help pages of your browser. Please note, however, that if you delete cookies or do not accept them, you will not be entitled to receive the Consideration defined in the Terms of Service.
5. Do you use any other user tracking technologies?