Octovid Limited – Privacy and Cookie Policy

Last updated July 2020

Introduction

Your privacy is important to Octovid Limited. This policy sets out information on the personal data we collect about you, and your rights in respect of this data. This policy applies whether you use our services (the “Services”) or use our app, Octovid Player, or our App (www.octovid.com) (the “App”).

Our App may contain links or redirects to third party websites that are not covered by policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.

If you have any comments on this policy, please email them to privacy@octovid.com.

This policy contains the following information (you can access a specific section of this policy by clicking below):

Who We Are

Our company name is Octovid Limited, a limited company registered in Ireland under company number 634576, whose registered address is 14a Magennis Pl, Dublin 2, Ireland. If you wish to speak to someone about the policy, please contact us on privacy@octovid.com

We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with General Data Protection Regulation (2016/679) and the Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with that.

What we may collect

Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you when you use our App or use our Services. Whenever we collect personal data about you, we must have a legal ground to do so.

When you create an account on our App

When you create an account with us, we will ask you to provide your name, email address, location and address, bank account information, company names and job titles, social media handles and websites. 

We use this information to allow you to sign into an account on our App. The legal basis for us collecting this information is legitimate interest – the information is required to protect your online account. We will use this information to provide the service of video advertising to you, via our App. Our legal basis for this is to perform a contract with you.

If you contact a member of our team to discuss customer service matters, we will use your name and email address when we interact with you. The legal basis we have for this is to provide you with assistance regarding customer service matters.

We will then use your name and email address to send you information about your account (including changes to this policy or security information). Our legal basis for using your name and email address in this way is to provide you with relevant information relating to the security of your online account, and also to ensure you have up-to-date information on how we handle your personal data.

We may ask you whether you want to opt-in to our marketing information. If you say yes to this, we will use your email address to provide you with marketing information about our products and services. Our legal basis for this is that you have provided your consent. You can withdraw your consent at any time by contacting us at privacy@octovid.com

Data from visitors to our App

We process data about you so that video adverts can be automatically personalised to you in real-time. The information we may collect is as follows:

  • First name and last name
  • Email address
  • Location information
  • IP address
  • URL and domain from which they arrived
  • Online identifiers, including data collected from customers’ devices, applications and protocols, cookie identifiers, device type, browser type and operating system
  • Page views and time spent on our app
  • Data and time when the website pages were accessed
  • Any specific information we may have received from our customer when producing video adverts for you (including your preferences, buying habits or other information)

We use all of this information to personalise your experience. Our legal basis for collecting this information is our legitimate interest to provide you with personalised, real-time video advertising.

Information in access logs of our customers (including IP addresses and dates and times our App is accessed) is kept by us for two weeks for security purposes, and then automatically deleted.

Information in access logs of visitors viewing the videos on our customers’ websites (including IP addresses and dates and times our App is accessed) is kept by us in order to provide a full understanding of the view count on the videos. This data is deleted monthly.

It is your responsibility to let visitors (including end users viewing your content) know that they are using our app, and that their IP address can be used to enhance their experience while watching videos. It is also your responsibility to inform those visitors that the app will be able to view those IP addresses and any other data sent by the visitor to enhance their experience.

Processing data of customers or potential customers

Where you use our App to contact your customers or potential customers (together, known as “customers”), you are the data controller and we are the data processor in terms of the Data Protection Legislation.

As you are the data controller, it is your responsibility to ensure that you have customer consent for collection of their personal data. We act as data processor, and comply with our obligations as a data processor.

If you are our customer, and therefore a data controller, you can access our data processing addendum here: https://octovid.com/legal/dpa/

Information on cookies

We use cookies in accordance with the Privacy and Electronic Communications Regulations (implementing the EU Directive 2002/58/EC).

Cookies are small text files placed on your device when you visit our site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the site however, for non-essential cookies we need your permission.

We use cookies to distinguish users and to improve our App. We analyse how you use our App, and we look at aggregate statistics about your usage, and how others use our App. We collect certain information from these cookies, and this includes information about your IP address, your location when you access the App, the date and time you access the App, the language you use and the type of browser you use.

We do not track individual users or use cookies to identify individuals. We use cookies to recognise you and your preferences, improve our site’s performance and collect analytical information for ourselves and our business partners. Without the knowledge gained we would not be able to provide the service we do.

These are the types of cookies we use.

  • ‘Session cookies’ allow us to track your actions during a single browsing session, but they do not remain on your device afterwards
  • ‘Persistent cookies’ remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our App

Session and persistent cookies can be either first or third party cookies. A first-party cookie is set by the App being visited; a third-party cookie is set by a different App. Both types of cookie may be used by us or our business partners.

The third party cookies we use are:

  • Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our App and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information
  • Facebook Ads (the Facebook pixel) – these cookies collect information about how visitors use our App. This data is collected anonymously and is used to help improve our App’s functionality
  • Google Ad Words – these cookies collect information about how visitors use our App. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our App’s functionality

All our cookies are categorised by the role they fulfil on our App:

a. Strictly Necessary: these are essential to enable you to move around our App and use features such as secure services. Without these cookies such services could not be provided;

b. Functionality: allow the App to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other Apps; and

c. Performance: collect information as to how users use the App. These cookies don’t collect information that identifies a visitor. The information collected is aggregated and used to improve our App.

d. None of the cookies employed are classified as Behavioural Targeting.

We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full App experience to you, including some elements of video advertising.

If at any time you wish to disable our cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our App (each time you access the App).

How we store your personal data

We store all your personal data on our servers, which are AWS EC2 servers, eu-west-1, Europe (Ireland). 

We (or our third party providers – detailed below) may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive our services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA. 

This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements. 

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.

Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our App. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA.

We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.

How we disclose your information

We may disclose your information in the following cases:

  • If we want to sell our business, or our company, we can disclose it to the potential buyer
  • We can disclose it to other businesses in our group, as defined in the Companies Act 2006
  • We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights
  • We can exchange information with others to protect against fraud or credit risks

We may contract with third parties to supply services to you on our behalf. These include cloud services used to send emails and technology providers that assist in providing services to you.

We also use: 

  • www.getgist.com for chat support & knowledge base
  • www.maxmind.com for location information
  • www.openweathermap.org for weather information
  • Third party stock libraries, including www.pexels.com, www.pixabay.com and www.unsplash.com 
  • https://malcolm.app for help file documentation and FAQs
  • Stripe Inc for payment processing (link to Stripe privacy policy: https://stripe.com/ie/privacy)
  • OAuth2 for our login system
  • Mailchimp for marketing communications
  • Google Tag Manager
  • CloudApp for use in our help and training videos
  • Productflare for manual feedback collection and app news/updates
  • Userback – used by us for manual screen grab / video feedback from users
  • Google sheets for tracking promotions
  • Tooltip.io for product tour and in-app notifications

If a subscriber to our App creates an email campaign, the email campaign platform (including MailChimp above) will send your personal data to our App, so that this information can be added to the video in real time.

Your rights

When you provide us with personal data, you have certain legal rights, and these include:

  • To request access to, deletion of or correction of, your personal data held by us at no cost to you
  • To request that your personal data be transferred to another person (data portability)
  • To be informed of what data processing is taking place
  • To restrict processing
  • To object to processing of your personal data
  • To complain to a supervisory authority

If you wish to access, rectify, erase or transfer your personal data, please contact us at privacy@octovid.com

What happens when we link to other websites

This privacy policy only relates to our App and our Services. We might have links on our App to other websites, and these websites will have their own terms and conditions and privacy policies. You should check those privacy policies before providing your personal data to those websites.

Please note that our terms and conditions and our policies will not apply to other Apps that you get to via a link from our App. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Notice for California residents of privacy practices and rights

If you are a California resident, California law may provide you with additional rights regarding your personal data.

Your rights

The California Consumer Privacy Act of 2020 (“CCPA”) gives you the following rights.

  • Right to know about the personal information we collect and share
    • The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you
    • Please see above for information on the data we collect on you, and how we process it
    • We do not sell your personal information. However, we do disclose your personal data to limited third parties, as described above
  • Right of deletion
    • You have the right to request that we delete your personal information, subject to certain exceptions
    • If you wish to delete your personal data, please contact us at privacy@octovid.com. Please note that we may require certain information from you in order to verify your identity before proceeding with your request

Disclosures about your personal information

We collect the categories of personal information from you in connection with your use of our App as described above.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights.

The changes we may make to this policy

We can update this policy from time to time as laws change or as our Services or Apps change. If we make material changes to the policy, and we need your consent to those changes, we will contact you by email to do so.