Last Updated: March 20222
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:
- Personal Data: We collect personal data about when you establish an account (bearing a unique log-in and password), and for billing/payment purposes.
- General Device Information: We collect information about your device type, i.p. address., Wi-Fi networks signals strength, battery level, time zone, network status, browser type, browser identifier, unique device identification number, and any other information that alone or in combination may be used to uniquely identify your device.
- TV Watching: We collect information about your TV watching patterns and preferences, including but not limited to, whether your TV is on or off, the TV channels you are watching, the time you watch each channel, ID of the TV and type of the TV, volume of TV, PVR viewing, VOD viewing etc.
- Online & Device Activities: We may collect data about the identity of the websites you visit, browsing history, the search terms you use and their results, apps used, apps installed, calls times and duration etc.
- Geographic Location: We may collect information regarding the location of your device (i.e., by requesting your permission to obtain geo-location data from your device and/or by obtaining geo-location information through Wi-Fi networks you are logged to). The geo-location information may be provided by the Services at any time, whether the App is open or not.
Legal Basis for Processing
VL will only process 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:
- As permitted by applicable law;
- Legal obligation - VL may process your personal data as necessary to comply with applicable laws and regulations (not including contractual obligations);
- Performance of a contract to which VL and you are parties; and
- Legitimate interests - VL may use your personal data where it has legitimate interests to do so. For instance, VL analyzes users’ behavior to continuously improve its App and VL processes information for administrative, fraud detection and other legal purposes.
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:
- To provide the Services and to enable you to use them;
- To improve and expand the Services. The information used by VL for this purpose will be mainly statistical information, and will not identify you personally;
- To improve and customize your experience and other users' experience with our Services;
- To contact you occasionally, either by VL or by a third party acting on our behalf, regarding VL’s Services and/or products;
- To contact you as and when VL believes it to be necessary for technical, administrative or security reasons;
- To analyze and provide statistical information to third parties. This information will not including personal data, and will not identify you personally;
- For the orderly and proper operation and development of the Services; or
Transfer of Personal Data to Third Parties
- If VL reasonably believes that it is required by law to share or disclose your personal data / information in order to prevent, investigate, or take action regarding illegal activities. In addition, to establish or exercise our legal rights or defend against legal claims;
- In response to lawful requests by applicable local law enforcement agencies or regulatory agencies, or agencies with responsibility to oversee and enforce national security;
- In any case of dispute or legal proceeding of any kind between you and VL, or between you and other users or third parties with respect to, or in relation with the Services;
- In any case where VL reasonably believes that sharing your personal data is necessary to prevent serious damage to your person or property or to the person or property of any third party;
- With service providers for the purpose of assisting VL to execute certain tasks outsourced to them, or providing VL with capabilities that it requires (and all such service providers do/will not have the right to use a user’s personal data beyond that which is necessary for the purpose of facilitating their services for VL’s benefit, and subject to data processing agreements between them and VL, as required under applicable law);
- Individual level data shared with VL’s business partners for such partners’ market research purposes';
- With third parties that may also have personal data / information about you, so that both VL and such third parties may jointly develop applications, offerings or services that will deliver a more customized user experience; and
- With companies or organizations connected to or affiliated with VL, such as subsidiaries, sister-companies, parent companies and service providers such as an email service provider to send you emails on our behalf, with the express provision that their use of such information must comply also with this policy.
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 VL for operational, administrative and compliance purposes;
- By VL’s sales, business partners, operational or customer support teams in our various locations; and
- By VL’s service providers, for the purposes we specified above under the section "Transfer of Information to Third Parties ".
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:
- Any transfers to VL affiliates in Israel may be made on the basis of an adequacy decision made by the European Commission.
- Model Clauses. With some of our processors, we use standard contractual clauses approved by the European Commission that are binding standards of processing of personal data committed to contractually by third parties processing information for us and on our behalf.
- In the absence of an adequacy decision and/or model clauses, and in the absence of any other right to transfer your personal data, your consent shall serve as the basis for such transfer. By accessing and using the Services, you agree and understand that your personal data may be transferred from the UK to other jurisdictions.
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:
- The right to be informed about how your personal data is being used;
- The right of access to your personal data processed by us, which includes the right to obtain confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, access to the personal data and the purposes of the processing; categories of personal data concerned; recipients or categories of recipient to whom the personal data have been or will be disclosed; where possible, the envisaged period for which the personal data will be stored; the existence of the right to request rectification or erasure of personal data or restriction of processing of personal data or to object to such processing; the right to lodge a complaint with a supervisory authority; where the personal data are not collected from the data subject, any available information as to their source; the existence of automated decision-making, including profiling; the appropriate safeguards relating to the transfer of your personal data outside the EEA.
- The right to request the correction of inaccurate personal data we hold about you;
- Under some circumstances, the right to request that we delete your data;
- The right to restrict processing of your personal data;
- The right to object to processing activities, if the processing is based on our legitimate interest;
- The right to withdraw consent for processing at any time, if the processing is based on consent;
- The right to object to processing of personal data for direct marketing purposes at any time;
- In some circumstances, the right to request that we transfer or port elements of your data either to you or another service provider – if the processing is based on your consent, and is made by automated means.
- The right to file a complaint with your Supervisory Authority (in the EEA, as prescribed by 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:
- Essential Cookies: These first party cookies allow users to use a feature within the Services such as staying logged.
- Analytics Cookies: These cookies track information about how the Services are being used so that we can make improvements and report on our performance. We may also use analytics cookies to test new ads, pages or features to see how users react to them. Analytics cookies may either be first party or third-party cookies.
- Preference Cookies: These first party cookies store your Services/features preferences.
- Ad Targeting Cookies: These third-party cookies (also known as "behavioral" or "targeted" advertising cookies) are placed by advertising platforms or networks to: (i) deliver ads and track ad performance, and (ii) enable advertising networks to deliver ads that may be relevant based upon your activities.
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?