We also collect other kinds of information from you or other sources, which we refer to as “Other Information” in this Policy, which may include but is not limited to:
- Information about your use of the Services, such as usage data and statistical information, which may be aggregated.
- Browsing history including the websites or other services you visited before and after interacting with the Services.
- Searches for and interactions with e-commerce opportunities, such as offers contained in the Services
- Non-precise information about the approximate physical location (for example, at the city or zip code level) of a user’s computer or device derived from the IP address of such computer or device (“GeoIP Data”).
- Internet Protocol (“IP”) address, which is a unique string of numbers automatically assigned to your device whenever you access the Internet.
- Device type, settings and software used.
- Log files, which may include IP addresses, browser type, ISP referring/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on customized links.
- Web Beacons, which are electronic files that allow a website to count users who have visited that page or to access certain cookies.
- Pixel Tags, also known as clear GIFs, beacons, spotlight tags or web bugs, which are a method for passing information from the user’s computer to a third party website.
- Local Shared Objects, and Local Storage, such as HTML5.
- Embedded Scripts which are programming codes designed to collect information about your interactions with the Service by temporarily downloading onto your device from our web server or a third party with whom we work. Embedded scripts are only active while you are connected to the Service and are deleted or deactivated thereafter.
Under certain circumstances and depending on applicable law, some of this Other Information may constitute Personal Information. Personal Information together with Other Information is hereinafter referred to as “User Information”.
By "Personal data" we mean information about any individual or from which any individual is directly or indirectly identifiable. This inlcudes your personal details (e.g., name); demographic data (e.g., age); contact details (e.g., address); records of your consents; purchase details; information about your interactions with our content or advertising; and any views or opinions you provide to us. We may also Process information about you from your use of our Services (e.g., the type of device you are using, the internet service provider, etc.), including your interactions with content and advertising on the Services.
By “Process”, “Processing” or “Processed” in the context of your personal data we mean anything that is done with any Personal Information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
There are three types of personal data we or our partners may collect from you:
- personal data you provide when authorizing via Twitch;
- any other personal data you chose to send to us via email or postal service.
- information about your computer and your position. This may include IP address, geo-location, operating system, number of visits and/or page views, referral page and browsing history on our website.
We may use analytics software (e.g. Google Analytics) to collect data and to better understand your behaviour on our site and your commercial preferences. This software may record information such as how often you use our website, the events that occur within the website, which pages you visit, aggregated usage, performance data, and where you reached our site from.
Certain third parties (Google AdSense) may collect information about you for online behavioral advertising (“OBA”) purposes in order for you to receive relevant interest-based advertising on the Services and on other websites, platforms and media channels. OBA is also referred to as interest-based advertising.
The specific providers we use for OBA are subject to constant change. Below you can find a list of some of the providers we use most often:
- Google Analytics
- Google Adsense
There are various reasons for which we collect your personal information.
When an account is created for you on your website, we will use this information to better administrate your account, improve your experience on the website by adding new features and services, to send you statements and invoices and/or verify that you satisfy the age restriction for certain products.
We may Process your User Information to contact you via email or other methods of communication to provide you with information regarding the Services that may be of interest to you. We may send information to you regarding the Services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law. We may also send you third party promotional content from one or more of our business partners.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in every email we send. We will not send you any emails from a list you have selected to be unsubscribed from, but we may continue to contact you to the extent necessary for the purposes of any other Services you have requested or for additional emails you have signed up for.
We may disclose your User Information to other entities for legitimate business purposes (including operating the Services, and providing services to you), in accordance with applicable law. In addition, we may disclose your User Information to:
- legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
- outside professional advisors (such as accountants, auditors, or lawyers), subject to binding contractual obligations of confidentiality;
- third party Processors (such as analytic providers; data centers, payment gateways; etc.), located anywhere in the world;
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
- any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
- any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation);
- any relevant third party provider, where our Channels use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, information about your activities on the Channels to provide you targeted advertising based upon your interests may be shared with the relevant third party provider. If you click or tap on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria;
With respect to surveys, in the event that responses are publicly disclosed, users will be notified at the time they take the survey. Otherwise we will disclose only aggregate information regarding its users’ responses in surveys to other participants in the survey. Where surveys allow users to submit written comments, and where PogTv advises users of the possibility of such disclosure at the time they take the survey, PogTv reserves the right to disclose any information provided by users, provided that no User Information identifying a specific user is disclosed.
Some of our advertisers may use third party advertising service companies to serve advertisements, for OBA or otherwise, and perform related services when you interact with the Channels. Often, these third party advertising companies employ cookies and other technologies to measure the effectiveness of website and email advertisements and to create a record of interaction with our content that they use in conjunction with their advertising which appears on other sites or applications, or for reporting website traffic, app use, statistics, advertisement data and/or other activities on the Services. We also engage third party providers to assist with the segmentation of this data.
We may engage third party providers to assist with the collection, storage and segmentation of Online Data and the providers are required to maintain the confidentiality of this information. These third party providers may collect User Information from our Services for their own purposes, such as to monitor fraud around the web.
If we engage a third-party Processor to Process your User Information, the Processor will be subject to binding contractual obligations to: (i) only Process the User Information in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the User Information; together with any additional requirements under applicable law.
Also, in order to store your personal data securely, we user third party software and databases that helps us to operate our store. This means that your data is safely stored (therefore also shared with) on third parties databases. The following list shows the current providers we use for this purpose but this list is subject to change at any time.
Due to the international nature of our business, we may need to transfer your User Information to third party providers as noted in the above sections, in connection with the purposes set out in this Policy. For this reason, we may transfer your User Information to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any Personal Information that you send to us is sent securely.
In compliance with applicable regulations, a system of anti-spam verification on the communication between users is active. The data entered may be verified for the sole purpose of identifying illegal activities or contents that do not comply with the PogTv Terms of Service, but will not be processed or communicated for commercial or promotional purposes.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of Processing, in accordance with applicable law. In certain instances we may use Secure Sockets Layer encryption and/or transfer certain User Information in a non-human readable format to provide protection. However, we cannot guarantee there will not be a breach, and we are not responsible for any breach of security or for the actions of any third parties.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement reasonable measures to protect your information, we cannot guarantee the security of your data transmitted to us using the internet. Any such transmission is at your own risk and you are responsible for ensuring that any Personal Information that you send to us is sent securely.
Your account information is kept on our systems for as long as you have an account on our system.
Newsletter subscriptions are kept as long as you continue to consent to receive our newsletter.
Finally, we remind you that the data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which has been implemented through the EU Directive 2017/541 on anti-terrorism regulations.
You can directly take steps to change your preferences for newsletters and online behavioral advertising as outlined in this section.
If you are an EU resident, you may have certain rights including: the right not to provide your Personal Information to us; the right of access to your Personal Information; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing of your Personal Information; the right to object to the Processing of your Personal Information; the right to have your Personal Information transferred to another controller; the right to withdraw consent; and the right to lodge complaints with supervisory authorities. We may require proof of or need to verify your identity before we can give effect to these rights.
You may directly take steps to change your preferences as follows:
Cookies and Pixel Tags. We may Process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. You may stop or restrict cookies and pixel tags on your computer or purge cookies from your browser by adjusting your web browser preferences. However, if you “turn off,” purge, or disable cookies or pixel tags, although you may still use the Services, you may not be able to use all of the features, functions, or services available on the Services.
EU Residents. GDPR provides certain rights for EU residents. You may decline to share certain information with us, in which case we may not be able to provide some of the features and functionality of the Services. These rights include, in accordance with applicable law, the right to object to or request the restriction of processing of your information, and to request access to, rectification, erasure and portability of your own information. Where we process your information on the basis of your consent, you have the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Information in reliance upon any other available legal bases). Requests should be submitted by contacting us via email at firstname.lastname@example.org. If you are an EU resident and have any unresolved privacy concern that we have not addressed satisfactorily after contacting us, you have the right to contact the appropriate EU Supervisory Authority and lodge a complaint.