Privacy Policy

Last Updated On: Dec 6, 2018

Highlights of BBTV’s Privacy Policy: • We only ask for your personal data to verify your identity and provide services to you. • We only collect and keep the data we need. • We only share your data if it’s required to provide our services. • We ensure your data is protected when we collect and share it. • We comply with major data protection regulation. • We don’t do business with minors under 13. • You can ask us to change/delete your data by emailing privacy@bbtv.com.

1. Introduction

We at BroadbandTV Corp., together with our affiliated companies (referred to collectively in this Privacy Policy as “BBTV”, “we”, “us” or “our”) are committed to respecting and protecting the privacy and security of your personal data obtained by reason of your relationship with us. We take your privacy seriously and believe that you should know what information we collect from you and how we use, disclose, and protect that information.

Please read the following to learn how this Privacy Policy applies to your access or use of our websites (including if you are using our website to partner with BBTV as a Content Provider ), mobile applications, and any product or platform we offer or through which we provide services.

2. Collection and processing of your data

Visitors to our websites:

Standard website traffic data. When you visit our websites or otherwise use our services, we collect your IP address and standard web log information, such as your browser type and the pages you accessed on our website. We also collect device specific information (such as your hardware model, operating system version, carrier network and hardware settings), information about your physical location (such as GPS signals, Wi-Fi access points, and cell towers), and information about your usage of an interaction with our services (including error reports, statistics on page views, and traffic to and from our websites). This data allows us to provide you with a better user experience on our websites. For example, if you are accessing our websites from a non-English-speaking country, this data allows us to provide you with a localized and translated version of our websites.

Cookies. We use “cookies” to enhance your use of our websites or other services. A “cookie” is a small amount of data, which include a unique identifier. Cookies are sent to your browser from a website and stored on your device. Every device that accesses our websites is assigned a different cookie by us. Providing us with your information is always your choice. However, we may not be able to provide you with all the services or functionality you require on a BBTV website if you choose to disable cookies.

Usage analytics. Our websites make use of industry-standard analytics frameworks, which track viewership and usage of our websites. Although these frameworks may receive your IP address, they do not provide any personal data to BBTV and are solely for the purposes of improving our websites.

Creators partnered with BBTV:

Personal data required to execute a Content Provider Agreement. If you are a contracted creator with BBTV (also known as Content Providers or partners), or if you have applied to join our network, we collect additional personal data from you that is directly associated with you or that can be used to identify you. This personal data includes your contact information, such as your name, user name, address, phone number, and email. We require this data to issue an agreement to you, to meet legal and regulatory requirements, to provide you with important communications, and to verify your identity in the future should you need to contact us.

Payment information. We also collect your payment method of choice. We use PayPal and other payment information you provide to us in order to provide you with payment for any services that you may provide to us in accordance with an applicable services agreement between you and BBTV.

Date of birth. Before permitting you to use any of our services, we also ask you to provide additional personal data we can use to verify your identity or manage risk, such as your date of birth.

BBTV’s services are not intended for users under the age of 13. We take children’s privacy seriously, and encourage parents to be aware and involved in the online activities of their children at all times to ensure that no information is collected from a child without parental permission. We do not knowingly collect the personal data of minors without parental consent.

Correspondence. We keep records of correspondence with our contracted Content Providers. Correspondence with BBTV is conducted through ticketing systems, email, or online chat mechanisms. We record this information to ensure adequate levels of service are being provided per your agreement with BBTV.

Content performance data. When you partner with BBTV, your platform will begin providing us with performance data about your channel and videos. This includes revenue and viewership data. This data is required to calculate payment to you as per your agreement with BBTV.

If you are a member of a jointly-operated network (such as NBA Playmakers), we share this performance data with the joint operator as well (such as the NBA).

Creators represented by BBTV in additional revenue opportunities:

Creator profile data. To effectively represent you in additional revenue opportunities (such as branded entertainment opportunities and mobile apps), BBTV creates and shares promotional materials about your channel with third parties who may be interested in working with you. This requires collection of data about your channel, such as the reach of your viewership, demographics of your audience, and a brief profile about you and your channel.

This information is collected from a variety of sources, including third party analytics tools and information you have shared with BBTV.

Content performance data. If we execute an additional revenue opportunity between yourself and a third party, we will share performance data with that party. The performance data we share will only be related to the opportunity in question.

Creators not contracted with BBTV:

Public channel or video metadata. If you make public your channel and content on digital platforms, we scan and catalog the metadata you have posted publicly. This is similar to how search engines index your content.

Correspondence with BBTV. We keep records of correspondence via email, our ticketing systems, online chat, and other means. We record this data for auditing purposes, to ensure effective communications, and to ensure compliance with laws and regulations.

Users of our network-exclusive products:

Authentication data. We keep data required to authenticate and verify your identity prior to use of our products. This is to ensure you meet the requirements for access of this product, as well as to prevent unauthorized use of your account or credentials.

Metadata you have provided during use of the product. Many of our products ask you for information to improve the quality of your profile, or enhance your experience with the product. For example, some of our products may ask you about your channel’s interests or topics.

Channel analytics. Some of our products collect performance analytics about your channel. This allows these products to provide you with enhanced reporting, analytics, and optimization functionality.

Usage analytics. Our products use industry-standard analytics tools to track and monitor usage of our applications. These analytics enable us to understand usage patterns for our products and make improvements to these products.

Users of our mobile products:

Account information. Many of our mobile products require the creation of an account. This requires you to provide a username, password, and other personal data which varies depending on the product. This data is used to verify your identity, track your progress, enable multi-player functionality, enable social features, and prevent unauthorized use of your username.

Mobile platform username. Your mobile platform, such as Apple or Google, may make your username available to us for use on leaderboards and as a screen name.

Usage analytics. Our products use industry-standard analytics tools to track and monitor usage of our applications. These analytics enable us to understand usage patterns for our products and make improvements to these products.

Targeting data for advertising. Our mobile apps leverage platforms such as Appodeal to serve advertisements. Advertising is non-targeted by default, and ad targeting will only be enabled if you explictly consent.

Users of our online stores:

Website visitor data. As our online stores are hosted on the web, the data collected in the “Visitors to our websites” section above applies here.

Purchase, billing, and shipping information. Fulfilling your purchase order requires the collection of your billing and shipping information. This will include your name, address, and credit card information.

BBTV uses Shopify Inc. as its online commerce solution. All data related to purchases from our online stores is managed by Shopify Inc.

Employees, contractors, or applicants:

Personal data required to process your employment or contract. BBTV collects only the minimum personal data required to execute your employment or contract. This includes your name, contact information, address, emergency contact, and preferred method of payment.

Job applications. Applications received via email or online submission contain your personal data, such as name, contact information, education history, and employment history.

If, for any reason, the information that we collect from you is required to fulfill a different purpose than for the purposes described in this Privacy Policy, we will inform you of this new purpose before we proceed.

Personal data and other information collected by BBTV is stored and processed on our servers in Canada or in the US. These servers may be located outside of the country where you live. All our servers comply with the adequacy requirements set forth by Regulation (EU) 2016/679 (also known as GDPR)

If you have questions or concerns about the transfer or processing of your personal data, you may contact us at privacy@bbtv.com.

3. Disclosure of the data that we collect

We disclose personal data to BBTV’s affiliates or affiliated companies when it is required in order to provide our services or fulfill operational or legal requirements. However, with respect to unaffiliated third parties, we do not share personal data with such parties except as permitted or required by applicable laws, rules and regulations and this Privacy Policy. We share your personal data with unaffiliated third parties in the following circumstances:

• If you consent to such disclosure. We require opt-in consent for the sharing of any sensitive personal data, such as confidential medical facts, racial or ethnic origins, political or religious beliefs or sexuality, or banking or other sensitive financial information. • To effect, administer, service, process or enforce a service that you request or authorize. • To enable additional revenue opportunities, such as branded entertainment campaigns or mobile apps, we may share your influencer profile with third-party brands. • To enable value-add services, we may share data with the third-party service provider so they can verify your partnership with BBTV. • To enable you to join our jointly-operated networks (such as NBA Playmakers), we may share your channel information and performance data with that joint operator (such as the NBA). • To protect the confidentiality or security of BBTV, our records or our users. • To protect against or prevent fraud, unauthorized transactions, claims, or other liability. • To resolve a dispute with you or an inquiry from you. • To persons acting on your behalf in a fiduciary or representative capacity. • To meet any applicable law, regulation, legal process or enforceable governmental request to comply with a civil, criminal, or regulatory investigation, or subpoena or summons by governmental authorities.

We also share your personal data with unaffiliated third parties that we have engaged to perform certain services in connection with the operation of certain aspects of BBTV’s services, such as payment processing, data management, and analytics. These service provider companies are provided only the information necessary to perform the services. In addition, we require them to protect the information in a manner that is consistent with this Privacy Policy and our security practices.

We share aggregated, non-personally identifiable information (that is, information that cannot, by itself, be used to identify a particular individual or user) with our third-party service providers, advertisers, advertising networks and platforms, and/or partners, such as advertising and marketing partners. For example, we may share such information to show trends about the general use of our services, to improve the design and content of such third parties’ respective offerings, to deliver more relevant marketing messages and advertisements, to enable us to personalize your Internet experience, and to perform analytics.

If BBTV is involved in a merger, acquisition, reorganization, asset sale, or other similar transaction or proceeding, we will continue to ensure confidentiality of any personal data and will give affected users notice before personal data is transferred or becomes subject to a different privacy policy.

4. Protection of the data that we collect

We maintain a variety of physical, electronic, and procedural safeguards to protect the information that we collect from unauthorized access. We use industry accepted procedures and systems to protect against unauthorized access to our systems. In addition, we use third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run the services. These vendors have been selected for their high standards of both physical and technological security, including ISO and SSAE16 certifications, as well as satisfying EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Economic Area (EEA) to the US. No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your personal data. We urge you to take every precaution to protect your personal data when you are on the Internet.

If you are logged-in, it is advisable that you log out of your account at the end of every session and not leave a logged-in account unattended for any period of time, particularly if you use a shared computer or device.

Unless it is otherwise permitted in this Privacy Policy, we restrict access to your personal data to those BBTV employees, agents and contractors who need to know that information to in order to process it for us, or to provide services to you or otherwise assist you, and that are legally bound to maintain the confidentiality of your information in a manner consistent with this Privacy Policy.

We maintain your personal data so that it is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. We encourage you to contact us at privacy@bbtv.com in order help us keep our information current.

5. Retention and deletion of personal data

We retain personal data for as long as is necessary to fulfill any of the purposes set out in Section 3 of this Privacy Policy, or to comply with applicable laws, rules, regulations, and regulatory requests and orders from competent courts and regulatory bodies.

6. Transfer of data outside the European Economic Area

We comply with Regulation (EU) 2016/679 (also known as GDPR). Under this regulation, residents of the European Economic Area (EEA) can expect their data to be properly secured when transmitted outside the EEA. We only conduct such transfers of your personal data when mechanisms are in place to protect it. These mechanisms can include transfer to countries where an adequate level of protection has been established, or to organizations compliant with the EU-US Privacy Shield Framework.

BBTV operates out of Canada, which is considered a country that provides adequate protections for personal data, as confirmed by the European Commission in Article 45 of Regulation (EU) 2016/679.

7. Your access to your personal data

You have the right to access the personal data we hold about you in order to verify the information and its accuracy. Please note that there may be instances where access may be restricted as permitted or required by applicable laws, rules and regulations, including information that is subject to legal privilege and information relating to a third party. If applicable, we will advise you of the reasons for restricting access subject to any legal or regulatory requirements.

We take reasonable steps to allow you to correct, amend or delete personal data that is shown to be inaccurate or incomplete. If you want to verify the personal data we hold about you, please contact us at privacy@bbtv.com.

To avoid delays, please provide sufficient information in order to allow us to identify you and the specific information you are requesting. Please give us a reasonable amount of time to respond to your inquiry.

8. Data protection for children and minors

BBTV takes children’s privacy very seriously and complies with the Children’s Online Privacy Protection Act (COPPA).

BBTV does not knowingly collect or process personal data from children under the age of 13. BBTV does not knowingly enter into contracts with children under the age of 13. In the event that BBTV has verified that a child under 13 has misrepresented his/her age in a BBTV agreement, BBTV will take immediate steps to either terminate that agreement or obtain the necessary consent from the child’s parent or legal guardian.

Minors who are 13 or older, but under 19 or their country’s age limit, may only enter into an agreement with BBTV if it is consented to, and co-signed by, his/her parent or legal guardian. We only collect the minimum personal data required to execute the agreement, and only with the consent of the parent or legal guardian.

Parents or legal guardians may request that BBTV disclose, update, delete, or restrict processing of data collected on their children. These requests can be made by emailing privacy@bbtv.com.

You can learn more about the online protections afforded to children from the FTC’s COPPA FAQ.

9. Rights for residents of the European Economic Area

We comply with Regulation (EU) 2016/679 (also known as GDPR). Residents of the European Economic Area (EEA) are entitled to rights regarding the collection, use, and protection of their data. These rights include:

• The right to access your personal data, and understand how it is collected and processed; • The right to rectify any errors or inaccuracies in your personal data; • The right to erase your personal data from collection or processing, where not in conflict with legal or operational requirements; • The right to restrict further processing of your personal data; • The right to receive exports of your personal data; • The right to object to the processing of your personal data; and • The right to exclusion from automated individual decision-making based on your personal data.

Residents of the EEA interested in exercising these rights may do so by contacting privacy@bbtv.com.

Additionally, residents of the European Economic Area (EEA) have the right to lodge a complaint with a supervisory authority. If you reside in the EEA and want to lodge a complaint, you may do so in the member state where you reside, where you work, or where you may have experienced an issue with the processing of your personal data.

10. Modification of this Privacy Policy

We reserve the right to change this Privacy Policy from time to time. We will post any changes to this Privacy Policy on this web page, and if the changes are significant, we will post a more prominent notice on this page or we will directly send you a notification. You agree that your continued use of the services after notice of such change shall constitute your acceptance of the Privacy Policy. You agree to review this Privacy Policy regularly in order to inform yourself of the terms and conditions of this Privacy Policy and any modifications to the Privacy Policy.

11. Application of this Privacy Policy

This Privacy Policy applies to all products and services offered by BBTV and its affiliates, including those offered on other websites owned by BBTV, but excludes products, services and agreements that have separate privacy policies that do not incorporate this Privacy Policy. Our Privacy Policy does not apply to products or services offered by other companies or individuals, including third parties who advertise our services, third party software or other products, or third party sites linked from our services. You must read the privacy policy of the third party to see how your personal data will be handled on their website.

12. Enforcement and complaints

We regularly review our compliance with this Privacy Policy and industry-recommended best practices, as well as applicable laws and regulations. Please contact us with any questions or concerns regarding this Privacy Policy or our treatment of your personal data. When we receive formal written complaints, we will contact the person who made the complaint to follow up.

13. Contact information

If you have any questions, comments or concerns about this Privacy Policy, or if you would like to exercise your rights over control and usage of your data, please contact us at privacy@bbtv.com, or using the contact details below:

Outside the European Economic Area (EEA):
Steve Kwan, Data Protection Officer
1205 Melville St.
Vancouver BC V6E 0A6
Canada
privacy@bbtv.com

Inside the European Economic Area (EEA):
European Data Protection Office (EDPO)
Avenue Huart Hamoir 71
1030 Brussels
Belgium
privacy@edpo.brussels