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VIPHO Privacy Policy

Last Updated: April 10, 2020

This Privacy Policy explains the information that VIPHO collects when you use its products and services, how that information is used, with whom it may be shared, and your privacy choices.

1. Introduction

Who we are and what we do

This Privacy Policy covers VIPHO Korea, Inc. (collectively, “VIPHO,” “we” “us” or “our”). We provide online video hosting, sharing and related services through our owned-and-operated websites, including Vipho.net and our branded applications for mobile and connected devices, and our AR video players (collectively, the “services”).

Acceptance and Changes

By registering for, downloading, or using our services, you accept this Privacy Policy, which is part of our Terms of Service. We may modify this Privacy Policy from time to time. We will post any modified version of our Privacy Policy at https://vipho.net/privacy.html If we change the Privacy Policy in a way that materially lessens our commitments to you, we will provide notice to registered users by email or other methods.

2. Children's Privacy

We do not knowingly collect personal information from individuals who are under the minimum required ages specified herein. You must be at least 16 years old, whichever is greater, to use our services. Individuals under the applicable age may use our services only through a parent or legal guardian's account and with their involvement. If you are a parent or legal guardian who believes your child has provided personal information to VIPHO without your consent, you may ask us to delete such information by contacting us at support@vipho.net.

3. Data We Collect About You

We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non-personal information. We refer to your information as "your data" for short.

Account Information

To create an account, you must provide a valid email address and password and name.

Content

Accountholders may create a profile and upload content such as videos, photo. Your profile may display information about you and your activities. Your videos may be viewed and otherwise accessed by others. You may choose to limit the availability of your profile and videos.

If you submit images or videos to us in connection with our video creation and editing tools, we may analyze such content using a variety of techniques, including machine-learning algorithms.

Information Collected by Third Parties

Some third parties may collect data about you when you use our services. This may include data you submit (such as payment information) or automatically-collected information (in the case of third-party analytics providers and advertising partners).

We may obtain data from third parties about you. We may combine that data with information that we have collected. For example, some advertisers or advertising platforms may allow us to determine what other online services you might use so that we may place relevant ads on those services.

4. How We Use Your Data

We may use your data for the following purposes:

We may use algorithms and other automated means to implement any of the above.

Whenever we process your data for one of these purposes, we have determined that one or more of the following lawful bases apply:

 

If you require further information about the balancing test that VIPHO has undertaken to justify its reliance on legitimate interest as a lawful basis of processing, contact us by email.

5. With Whom We Share Your Data

We share data with third parties as follows:

We use reasonable efforts to vet vendors for their privacy and data security practices. We require that such vendors agree to protect the data we share.

6. Legal and Safety-Related Disclosures

We may disclose your data in response to official requests (e.g., court orders, subpoenas, search warrants, national security requests, etc.) ("requests") that we receive from government authorities or parties to legal proceedings.

We handle U.S. requests in accordance with U.S. law. If the request originates from a foreign jurisdiction, we will typically disclose information where we in good faith believe that disclosure is permitted by both U.S. law and local law. In all cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

We may disclose user data where we reasonably believe that someone's life is at risk. For example, if we become aware of a person threatening to commit suicide, we may share that person's data with appropriate entities that may have the ability to help.

We may disclose user data to report suspected crimes. We report content suspected of exploiting minors to the National Center for Missing and Exploited Children (NCMEC) along with the data identifying the uploading user.

We may disclose user data in situations involving legal claims against us or one of our users. If you submit a Digital Millennium Copyright Act (DMCA) or other takedown notice, we may share that notice with the affected user. If you challenge such a notice, we may share your response with the complainant.

We may share your data with potential transaction partners, advisors, and others in the event our company is, in whole or part, acquired by a third party. In such case, we will use reasonable efforts to require the acquiring entity to comply with this Privacy Policy.

7. Data Retention

We retain your data for as long as you have an account. When you close an account, we will delete its content, including its videos. We may retain logs of automatically collected information (for internal analytics and security purposes); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a business reason for retaining data, we will delete or anonymize it.

Once we delete a video and photo, we may not be able to recover it. If you have previously made a video public, the video or its thumbnail may be discoverable in a search engine's cache for a time. We have no control over search engines; however, we will, upon request, send a request for deletion to major search engines.

If we receive legal process pertaining to your account, we will retain your data for as long as we in good faith believe is necessary to comply with the legal process. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your data to defend or assert our rights.

8. Your Privacy Choices

We enable you to make numerous choices about your data:

 

Users in certain jurisdictions may have additional rights. See Section 13 for more details.

9. Communications from Us

Emails

If you create an account, you may receive commercial emails from us. This includes newsletters and offers. You may always opt out from receiving commercial messages in your account settings. Please note that any opt-out request may take several days to process and you will continue to receive transactional emails from us (e.g., emails confirming transactions and/or providing information about your account).

Mobile Device Communications

We may, with your consent, send push notifications in our apps. You may disable these by declining them or changing the app's settings.

10. Protecting Your Information

We use physical, technical, and organizational security measures to safeguard your data from unauthorized or accidental disclosure. Despite these efforts, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Users also have a role to play in keeping their data safe. We encourage you to use a unique and hard-to-guess password for your account and to not share it with others. You should only grant access rights to people who you know and trust, and, even then, you should be careful in granting all access rights. You should monitor your account regularly. If you believe that someone has gained access to your account without your permission, please contact us immediately so that we can investigate.

11. Your Responsibilities

You may receive other people's data in using our service. If you receive information from other users, you must comply with all laws, including those concerning privacy, data security, and online marketing.

12. Third-Party Services

We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. For example, if you click on an advertisement, you may be taken to the advertiser's website. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.

You may use our service through third-party sites and to send you offers. For example, you may watch a video that is embedded on a third-party site or use one of our apps on a third-party platform. This Privacy Policy covers our apps. but does not cover any third-party site.

13. International Data Transfers and Certain User Rights

13.1 Location of Data

VIPHO is based in Republic of Korea. We provide services globally using computer systems, servers, and databases located in the U.S. and other countries. When you use our services from outside of the U.S., your information may be transferred to and processed in the U.S.. Please note that U.S. data and privacy laws may not be as comprehensive as those in your country. Residents of certain countries may be subject to additional protections as set forth in Sections 13.2 and 13.3 below.

13.2 GDPR (EEA Users)

This Section 14.2 applies only to natural persons residing in the European Economic Area (for the purpose of this section only, "you" or "your" shall be limited accordingly). It is VIPHO's policy to comply with the EEA's General Data Protection Regulation (GDPR). In accordance with the GDPR, we may transfer your personal information from your home country to the U.S. (or other countries) based upon the following legal bases:

You have the right to: access, correct, delete, restrict, or object to our use of your personal information; be forgotten; port your data; and withdraw consents. We enable exercise of these rights primarily through our services (which we reserve the right to modify). For example, we allow users to change their information, download their videos, and close their accounts. We also fulfil our obligations in response to direct requests. We will endeavor to process requests within one month. Please note that we may not be able to comply with requests to the extent that they would cause us to violate any law or infringe any other person's rights. We reserve the right to request appropriate identification. We will process requests free of charge unless they would impose an unreasonable cost on us.

If you have a request, complaint or inquiry, please contact our Data Protection Officer at the address listed in Section 14. We are committed to working with you to obtain a fair resolution of any issue. You also have the right to file a complaint with the supervisory data protection authority of your jurisdiction.

13.3 Privacy Shield (EEA, UK and Swiss Users)

This Section applies only to natural persons residing in the European Economic Area, the United Kingdom and Switzerland (for the purpose of this section only, "you" or "your" shall be limited accordingly). VIPHO complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework (collectively, "Privacy Shield") as established by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the EU, the United Kingdom and/or Switzerland, as applicable, to the U.S.

VIPHO adheres to the Privacy Shield principles of notice, choice, onward transfer, security, data integrity, access, and enforcement (the "Privacy Shield Principles"). VIPHO has established policies and procedures to ensure compliance with the Privacy Shield Principles and will conduct an annual internal assessment to ensure such compliance. If there is any conflict between the terms of this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

VIPHO has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view VIPHO's certification, please visit https://www.privacyshield.gov. By making this certification, VIPHO is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Where VIPHO has transferred personal information of EEA, UK or Swiss residents to third parties, VIPHO shall be liable if those third parties do not process personal information in compliance with the Privacy Shield Principles. This shall not be the case where VIPHO establishes that it is not responsible for the damage caused by the third party.

In accordance with Privacy Shield Principles, VIPHO commits to resolve complaints about our collection or use of your personal information. If you have inquiries or complaints regarding our Privacy Shield policy, you should first contact VIPHO at the address listed in Section 14. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact our independent recourse mechanism provider, JAMS, at https://www.jamsadr.com/eu-us-privacy-shield, to file a complaint. JAMS' services are provided at no cost to you.

If you have an unresolved complaint after contacting both VIPHO and JAMS, you may elect to arbitrate your Privacy Shield claims against VIPHO pursuant to Annex I of the Privacy Shield Principles, which provides for binding arbitration administered by the American Arbitration Association. Such arbitration will be binding upon you and VIPHO.

13.4 California Users

Under California’s “Shine the Light” law, California residents have the right to opt out of disclosing information to third parties for the purpose of allowing such third parties to directly market their products and services. At this time, we do not engage in this type of disclosure.

Under the California Consumer Privacy Act (“CCPA”), California consumers have the following rights, which can be exercised directly or in certain cases, through an authorized agent:

·  Right to Know. You have the right to request information about the categories and sources of personal information we collect, our purposes for collecting the information, and the types of third parties that receive that information. Details about our data collection, use and third-party disclosures can be found here. In addition, you have the right to request a copy of your personal information. You may exercise this right once per 12-month period by using this form.

·  Right to Delete. You have the right to request that we delete some or all of the personal information that we have about you. Deleting all data will typically require the deletion of your account, along with all content, including your videos. Notwithstanding the foregoing, we may retain information to provide services you have ordered, complete transactions, honor opt-outs, prevent fraud, spam, and other abuse, comply with our legal obligations, cooperate with law enforcement, and to exercise and defend our rights. You may exercise your right to delete by mailing to support@vipho.net

·  Do Not Sell. You have the right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months. VIPHO does not sell personal information. If we begin to do so, we will update this notice and provide a mechanism to opt out of any such sale.

·  Non-Discrimination. We won’t discriminate against you because you exercise any rights herein.

To exercise your rights to know and delete, we must be able to verify your identity as the owner of the VIPHO account you are inquiring about. We may not be able to fulfill your request until we can do so. In general, we verify identity by confirming that you are the owner of the email address associated with the account. An authorized agent submitting a request on your behalf must also have access to the email address associated with the account, along with sufficient evidence that you have authorized that person to submit the request on your behalf. Although you need not have a VIPHO account to submit a request, we may not be able to locate certain information to process your request if you don’t have one.

13.5 Nevada Users

Nevada residents have the right to opt out of the sale of certain "covered information" collected by operators of websites or online services. We currently do not sell covered information, as "sale" is defined by such law, and we don't have plans to sell this information. However, if you would like to be notified if we decide in the future to sell personal information covered by the Act, you can provide us with your name and email address. You are responsible for updating any change in your email address by the same method and we are not obligated to cross-reference other emails you may have otherwise provided us for other purposes. We will maintain this information and contact you if our plans change. At that time, we will create a process for verifying your identity and providing an opportunity to verified consumers to complete their opt-out. Please become familiar with our data practices as set forth in this Privacy Policy. We may share your data as explained in this Privacy Policy, such as to enhance your experiences and our services, and those activities will be unaffected by a Nevada do not sell request.

14. How to Contact Us

For any questions, inquiries, or complaints relating to your privacy, please contact us at:

VIPHO Korea, Inc.
Attention: Data Protection Officer
10F. 8,Gangnamdaero 69, Seocho, Seoul.

support@vipho.net