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Privacy

VEELY PRIVACY POLICY

Introduction and scope

This privacy and cookies notice applies to the processing of personal data, including information we collect and store via cookies, as explained below by Little Dot Studios Limited.  All personal data processed for the purposes of providing programming via our Veely App is processed in accordance with Data Protection Laws.


For the purposes of this privacy notice, Data Protection Laws means the California Consumer Privacy Act (CCPA), UK Data Protection Act, UK General Data Protection Regulations, EU General Protection Regulations and the Australia Privacy Act 1988 and any and all implementing legislation, regulations and all amendments thereto.


If you reside or are interacting with the Veely App in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share via the Services), your acceptance and viewing of the content via the Veely App is your explicit consent for the purposes of this Privacy Policy.  Should you wish to revoke your consent, please contact apps@littledotstudios.com.


References in this policy to “LDS”, “we” “us” or “our” should be interpreted accordingly.

Note that if you access the products and services of other LDS companies, you should refer to their privacy notices.

Types of information we process and where it comes from

(a) Information you've provided to us, including through our websites or when you access our services through applications on websites operated by other organisations.

(b) Information, uploads, user generated content, and comments you make about, or generate, in accessing the shows, channels, programmes, advertisements, products and services you use, for example, how you access and view the programmes.

(c) Information we collect, via cookies and related technology, from the devices you use to receive LDS content, products and services, about your use of LDS, and/or third party content, products and services. This includes information about your device, machine or browser which can be collected when cookies are turned off.  For more information on cookies and how to manage them, please see the section on cookies.

(d) IP address, MAC address, unique identification number, online identifier, browser information, location data port information, logical network address, and other similar identifying information required for your devices to communicate with websites and applications on the internet.

(e) Technical information from the devices you use to receive LDS content, products and services, for example, the collection of diagnostic and traffic or location information. Note that devices and applications have their own privacy settings and notices under which they collect your information, so please check and manage your device and application settings.


Why we may use your information

The main purpose for which we process your personal data is so that we can provide you with content, products and services. This includes customer support (including diagnostics and trouble-shooting), call screening and blocking, and tailored and personalised recommendations. 

In addition, we also use your personal data for the following legitimate business purposes:

(a) Managing our services and traffic across our network. For example, LDS uses your information to facilitate the operation of its network by choosing the most efficient route to transmit your requests for a communications service through the various parts of its network of equipment and systems. This information is held securely within restricted areas, accessible only by authorised personnel and in accordance with our data retention, deletion and acceptable use policies;

(b) Improving our content, products, services and customer experiences by monitoring your use of our products and services and working with our suppliers to improve the products and services we offer, and develop new content, products and services;

(c) Monitoring, recording, storing and using customer service communications we have with you. This helps us to improve the quality of our customer service, to confirm any instructions you give us, to create a customer profile to have better conversations and/or for training, development and to meet our legal and regulatory responsibilities.

(d) Showing adverts to the people most likely to be interested in the products and services being promoted. To do this, we create a profile about you which we use to define groups of audiences to whom we send adverts, based on factors like interests, age, location and more. As part of showing these adverts, we also carry out quality and frequency checks, such as whether adverts were displayed correctly and how often particular adverts have been shown.

(e) For market research.

(f)  Protecting or enforcing our rights or the rights of any third party such as by analyzing activity on our network to help block unauthorized or illegitimate content, publication of, or access to it.

(g) Complying with our legal and regulatory obligations (for example, in the context of police investigations and national security).


How we share your information

We work with a number of suppliers to process your personal data for the purposes described above. These suppliers act on our behalf and must only process your personal data in accordance with our instructions and are only granted access for the limited purposes for which such services are retained. The categories of suppliers that we use include:

Third party television platforms around the world

IT companies for hosting and server co-location services, cyber security, fraud detection, web analytics, session and activity recording services, remote access services, social and advertising networks;

Customer service centres operated by the platforms;

Service providers who work with us to allow us to meet our obligations as a listed entity

Marketing companies that deliver our communications

Advertising agencies and networks that deliver our advertising

Content licensors on an anonymised basis

Legal compliance in response to government and law enforcement officials in response to search warrants, court orders or similar. Such disclosures or access may occur if we believe in good faith that (i) we are legally compelled to do so; (ii) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding or suspected illegal activity, fraud or something analogous thereto.


Where our suppliers are based outside of the European Economic Area, we grant these suppliers access to personal data only if appropriate measures and controls are in place to protect your personal data in accordance with applicable Data Protection Laws.  More information can be obtained about this processing by contacting us as described in this notice.


How we share your information with Trusted Partners

Digital advertising enables us to provide you with access to the LDS Content on our Veely App free of any subscription charges. We work with a number of trusted partners to process your personal data for online and digital advertising purposes. This includes data like your IP address and device ID, which are required to serve advertisements to your device in your relevant location. We will never share your name, physical address or phone numbers with any of our trusted partners. We perform due diligence before a company becomes a trusted partner and is able to handle your data in a secure and responsible manner. The categories of partner that we work with include:

(a) Advertising agencies and advertisers, which buy advertising on LDS’s online and digital platforms so they can deliver advertising to your device that is suitable to your location and device; and  

(b) Advertising platforms (e.g. Google, SpotX, Axiom) which help LDS to deliver advertising across LDS’s online and digital platforms that are suitable for reception to your device and location. These advertising platforms enable LDS to offer its advertising space and manage use of that advertising space efficiently.

More information can be obtained about this processing by contacting us as described in this notice.

 

You can contact us via apps@littledotstudios.com amend or correct your information.  You also have the following rights:  

to request access to, or erasure of, the personal data we hold about you 

to request us to restrict the processing of the personal data we hold about you

to object to us processing personal data relating to you

where you have given us consent to process your personal data, you have the right to withdraw that consent at any time

you have the right to obtain certain personal data from us in a format that can be transferred electronically to a third party (also called “data portability”).

 

Please note that some of these rights are not absolute. In some cases, we may refuse a request to exercise particular rights if complying with it meant that we are no longer able to meet our contractual obligation to provide you with particular products and services.   However, we will keep you informed as to the actions that we can take, when you make your request.  

 

Data Retention and Location

Data Location: Your personal data is maintained, processed and stored by us and our authorized Service Providers (defined below) in the US, EU, UK, Australia. We may also retain your personal data in other locations as reasonably necessary for the proper performance and delivery of our App, or as may be required by law. LDS is headquartered in the United Kingdom, a jurisdiction which is considered by the European Commission as offering an adequate level of protection for the personal data of EU Member State residents.  While privacy laws may vary between jurisdictions, LDS, its affiliates and service providers are each committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in their jurisdiction. For data transfers from the European Economic Area (EEA) or the UK, that are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into standard contractual clauses as approved by the European Commission and the UK. You are entitled to request a copy of the standard contractual clauses used in these cases, and may do so by contacting us at notices@littledotstudios.com.

 

Data Retention: We will retain your personal data for as long as it is reasonably necessary in order to provide our service and offerings to you; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and applicable laws. Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete, anonymize or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us at notices@littledotstudios.com.