ShortsTV+ Privacy Policy

Last updated: 22 September 2021.

Shorts International Limited (we, our, us) are committed to protecting and respecting your privacy. Our contact details are as follows: Address: Shorts International Limited, 64 Great Eastern Street, London, EC2A 3QR, UK, telephone: +44 207 613 5400, email: legal@shorts.tv.

U.S. Users: Please be advised, as stated in our Terms, that choice- and conflict-of-law statutes and regulations in the United States specifically do not apply to your relationship with us.

SCOPE OF POLICY
This policy (together with any applicable end-user licence agreements (EULA) and Terms of Use and any additional terms of use incorporated by reference into the EULA or Terms of Use) shall together (our Terms) apply to your use of our services, which includes the ShortsTV and ShortsTV+ website, the ShortsTV, ShortsTV+, and any other, applications we make available (collectively, the “Services”).

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By accessing our Services you authorise us to collect, store, access, transfer and use your information as described in this Privacy Policy. If you don’t understand anything written in this Privacy Policy, you may seek legal counsel. If you choose not to seek legal counsel, please do not use our Services unless you specifically understand and agree to each of the provisions contained herein.

For the purpose of the Data Protection Act 2018 (“Data Protection Laws”), as amended, replaced or supplemented from time to time, the data controller is Shorts International Limited (address as above).

INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:

• Information you give us (Submitted information):: This is information you give us about you by setting up an account and/or filling in forms on our Services, or by corresponding with us (for example, by e-mail).
• It includes information you provide when you register to use our Services, or otherwise subscribe to any of our Services, request information about our featured content, or when you report a problem with our Services. If you contact us, we will keep a record of that correspondence including any identifying details which may be provided as a result of that correspondence.
• The information you give us may include your full name, date of birth, address, e-mail address and telephone or mobile number, username, password and other registration information, payment information, gender, information when you provide details of favourites, any content preferences or settings and taste preferences or content reviewing or rating and playlists or channels.
• Information we collect about you and your Device: Each time you use one of our Services, we may automatically collect the following information as applicable:
  • technical identifying information, including the IP address, the browser or device type , a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device, or the mobile phone number used by the Device), mobile network information, your device operating system;
  • details of your use of any of our Services including, but not limited to traffic data, general viewing activity and use data including choice of content, search queries made, communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Location information: We use your Device’s IP address to determine your current location.
• Cookies: When you use our Services, we utilize cookies and similar technologies (together, “Cookies”).
  • What are Cookies? Cookies are small pieces of text used to store information on web browsers or Devices. Cookies are used to store and receive identifiers and other information on computers, phones and other Devices. Other technologies, including data we store on your web browser or Device, identifiers associated with your Device, and other software, are used for similar purposes.
  • Our Cookies: The Cookies we use help us to authenticate you as a Subscriber and ensure the security and integrity of the Services, optimize different parts of your user experience, such as to encourage high display performance and to continue to present information when an internet connection might not be available. The functionality of the cookies we use includes the use of locally-stored Device information, such as your email address. The Cookies we use are essential for our provision of the Services to you and cannot be turned off. To learn more about cookies generally and how they impact your experience online, you can visit http://www.whatarecookies.com/.

USES MADE OF THE INFORMATION
We use information held about you in the following ways (with the legal basis for such use provided in brackets):

• to provide you with content, products, services, tailored and personalised recommendations, general account management, processing of subscription payments, and the management of traffic across our network; (Performance of a Contract);
• to make suggestions and recommendations to you of the content that may interest you and to organise information you have stored in your settings and provide information about other content we offer that are similar to those that you have viewed or favourited; (Performance of a contract and Legitimate business interests and the interests of our customers);
• to enable us to comply with any legal or regulatory requirements; (Compliance with a legal obligation);
• to determine from which country you are accessing or attempting to access our Services and to manage the content that is made available to you based on your location, and to provide, if applicable, localised Services and related content; (Performance of a contract and Legitimate business interests and the interests of our customers);
• to send you marketing about our Services (if you have opted in to receive marketing); (Consent);
• analysis of our user demographic; (Legitimate business interest);
• Please be advised that if we store any non-identifying information about you in a manner which could possibly serve to identify you, such as through coupling with identifying information, we will treat that information as we do our specifically identifying information.

Please be advised that if we store any non-identifying information about you in a manner which could possibly serve to identify you, such as through coupling with identifying information, we will treat that information as we do our specifically identifying information.

OTHER PLATFORMS
Our Services may be provided by third party platforms (such as smart TVs) or contain links to access services provided by third-party platforms, that have their own terms of use and privacy policies. These third-party platforms do not operate under this Privacy Policy or our Terms. These third-party platforms may independently solicit and collect information, including personal information, from you. You should read and take note of any applicable third-party terms of use and privacy policies before you use their services, as we will not be liable or responsible for the provision of your identifying information to any third-party platforms.

CHILDREN
Please note that you must be 18 years of age or older to set up an account on any of our Services. Individuals under the age of 18 may only use our Services where supervised by an adult meaning someone over the age of 18 years old.

As noted in the Terms, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for our Services or send any personal information about yourself to us. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that a child under 18 may have provided us personal information, please contact us.

For United States residents, if you are the parent or guardian of a minor child under the age of 18 whom you believed to have provided us with personal information, please contact us as above so that we may immediately delete that information.

DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.

We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Shorts International Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
• In order to:
  • enforce or apply the EULA, Our Terms, and other agreements or to investigate potential breaches; or
  • protect the rights, property or safety of Shorts International Limited our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
• We use other companies, agents or contractors (“Service Providers”) to perform tasks on our behalf and need to share your information with them to assist us with the provision of our Services to you; for example, we may use an analytics company to provide us with insights about your use of the Services, or other Service Providers to provide marketing, advertising, communications, infrastructure, IT and payment services, for example to process credit card transactions or to process and administer consumer surveys. Unless we tell you differently, our Service Providers do not have any right to use the personal information we share with them beyond what is necessary to assist us.
• User Profiles and Submissions: Certain user profile information, including your name may be displayed to other users; for example, if you choose to share a comment on a particular film or in a chat room (at such time as our Services provide). Your account privacy settings may allow you to limit the other users who can see the personal information in your user profile and/or what information in your user profile is visible to others. Please remember that any content you upload to your public user profile, along with any personal information or content that you voluntarily disclose online in a manner other users can view (e.g. comment sections) becomes publicly available, and can be collected and used by anyone. Your name may also be displayed to other users if and when you make comments through our Services.

WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored encrypted on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes and we will endeavor to obtain your consent. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us (details in the Contact Us section).

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.

If you are unhappy with the way we are processing your personal data, please email us. If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority in the country where you are using the Services.

You have the right to obtain a machine readable copy of your personal data, which you can use with another service provider. If we are processing data in order to perform our obligations to you, or because you consented, if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems. If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

You may have additional rights based on where you are using the Services. For example:

California Resident Rights:

Under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, companies have to provide certain disclosures about use of data of Californian residents’ information and provide certain rights (for example, to access and/or to delete data) to users. We have outlined above what data we collect and how we use it. Please contact us if you would like any further information or you would like to exercise any of your rights under CCPA.

DATA RETENTION AND DORMANT ACCOUNTS
We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this privacy policy.

If you have not used your account in the last 12 months, then your account may be classed as dormant or may be deleted. We will email you to remind you before deletion so please check your inbox to see if we have sent you emails about this.

If you would like to delete your account, please email customerservice@shorts.tv. We will delete all personal data in your account and any data we hold about how you have used our Services will be made anonymous.

ACCESS TO INFORMATION
The Data Protection Laws gives you the right to access information held about you. Your right of access can be exercised in accordance with those laws.

INTERNATIONAL DATA TRANFERS
Information that we collect may be stored or accessed outside the European Economic Area (“EEA”). We will ensure that appropriate transfer mechanisms are in place.

CHANGES TO PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail or when you next use one of our Services. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of our Services. Please be advised that your continued use of our Services constitutes your acceptance of the updated Privacy Policy provisions.

CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Shorts International Limited, address as above, or legal@shorts.tv.