ClouPlay Privacy Notices

 

These privacy notices provide important information about how ClouPlay, Inc. (“ClouPlay”) collects, uses,
processes, protects, and discloses information when you use the ClouPlay Websites and the ClouPlay Platform.

Our Privacy Notice for the ClouPlay Websites details the kinds of Personal Information we collect when you visit
the various websites that we operate and how we manage and use that information.

Our Privacy Notice for the ClouPlay Platform details the kinds of Personal Information that are collected when
you use or interact with the ClouPlay Platform through an Account Owner’s account.

These notices include legal information about your privacy rights, how you can exercise your legal rights, and how to
contact ClouPlay.

ClouPlay may update these Privacy Notices at any time without prior notice. Any such changes will become effective
prospectively from the date of publication. These Privacy Notices were last updated on April 6, 2020. We encourage you
to check this page frequently for any changes to our Privacy Notices.

Any inquiries, concerns, or requests regarding the use or disclosure of your Personal Information should be directed to
ClouPlay’s data protection officer at: [email protected]

Privacy Notice for the ClouPlay Websites

This privacy notice contains important information about how ClouPlay, Inc. (“ClouPlay”) collects, uses,
processes, protects, and discloses information when you use the ClouPlay Websites.

Please visit the Terms of Use for further conditions governing your use of
the ClouPlay Websites.

  1. What this Privacy Notice covers

This policy describes how ClouPlay treats Personal Information that we collect, receive, process, store, distribute,
and display via the ClouPlay Websites, including email, text, and other electronic communications between you and
ClouPlay.

For our privacy notice on information collected on the ClouPlay Platform visit: Privacy Notice for the ClouPlay
Platform.

In this policy, “you” means any person or organization that is authorized to use the ClouPlay
Platform or Website; “we” or “us” means ClouPlay, including our subsidiaries and
affiliates.

The “ClouPlay Websites” or “Websites” are websites and apps belonging to ClouPlay.

Marketing Partners” are trusted third parties providing us with services and data for marketing
purposes or conducting joint marketing activities with us.

Personal Information” is information about you that is personally identifiable by name or can be
linked to you through a personal identifier like your address, e-mail address, phone number, or location. This
definition is given here for the purpose of this notice only, and some laws may use a different definition. If you
are asserting your rights under law, the applicable legal definition governs your rights.

  1. When does ClouPlay collect Personal Information?

In general, ClouPlay collects Personal Information about you in the following situations:

    • When you visit the ClouPlay Websites
    • When you register through one of the ClouPlay Websites for online or in-person events organized by ClouPlay
      and/or our business partners
    • When you sign up to receive ClouPlay’s email newsletter, blog updates, or other communications from ClouPlay
    • When you participate in a ClouPlay survey
    • When you communicate with ClouPlay, post information to a blog or community forum, or upload user submitted
      media.
    • When you enter promotions and contests offered by ClouPlay
    • When you submit your resume or other Personal Information through the ClouPlay Websites in connection with a
      job application

Provision of this information to ClouPlay is not mandatory. However, you will not be able to access and use the
ClouPlay Websites and communicate with ClouPlay without disclosing some Personal Information to ClouPlay.

  1. What categories of Personal Information we collect

Through the ClouPlay Websites, we may collect Personal Information that you voluntarily provide, such as your name,
email address, location, professional title and affiliation, and interests. We also record your communications
preferences when you sign up to receive email communications from ClouPlay.

In addition, like most other websites, when you visit any of the ClouPlay Websites, ClouPlay automatically receives
and records information from a variety of sources, such as information from your browser, device, ClouPlay and
third-party cookie information, web beacons, VAST tags, pixel tags, social media buttons, URL links, and other
methods. Information collected automatically through these sources include your activity on the ClouPlay Websites and
unique identifiers such as your IP address and device ID.

We collect Personal Information about potential business customers and partners from our Marketing Partners and
public sources.

Although some information collected automatically is not personally identifiable, we or our Marketing Partners may,
to the extent permitted by applicable law,  aggregate or combine this information with information from other
sources, both public and non-public (such as data brokers and organizers of conferences you attended who have your
permission to transfer information to us, and information available publicly on the Internet). Combining information
from various sources could make anonymous information identifiable as Personal Information or add to the Personal
Information we already have about you.

  1. The purposes for which we use your Personal Information

We use your Personal Information from the ClouPlay Websites solely for certain legitimate business purposes, which
include some or all of the following:

    • Contacting you and sending you communications that we think will be of interest to you.
    • Providing you the information you request through our Websites.
    • Remembering information you previously entered on our Websites to enhance, modify, personalize, or otherwise
      improve your experience on our Websites.
    • Improving our Websites, services, and products.
    • Customizing the advertising and content you see.
    • Conducting research and providing statistical reporting to understand how individuals interact with our
      Websites and determine the effectiveness of promotional campaigns and advertising.
  1. Children

The ClouPlay Websites are not intended for children and we do not permit children to register on ClouPlay Websites.

If we become aware that we have inadvertently received or collected Personal Information pertaining to a child under
the age of consent in the jurisdiction where the child is located without valid consent, we will delete such
information from our records.

  1. Cookies and other activity tracking technologies

We use cookies and other technologies such as web beacons, tags and other technologies to collect information about
usage of ClouPlay Websites and interaction with emails that we have sent.

When you visit ClouPlay Websites, our servers or an authorized third party may place a cookie on your browser. The
cookie can collect information, including Personal Information, about your online activities. Cookies allow us to
track usage of the ClouPlay Websites and provide you with a better browsing experience.

We also use web beacons on the ClouPlay Websites. For example, web beacons may be placed in marketing emails to
notify us when you click on a link in the email and are directed to a ClouPlay Website. Web beacons are used to
improve the ClouPlay Websites, enhance our email communications, and track the success of our promotional campaigns.

Please see below for details about how we use different categories of cookies and other tracking technologies, as
well as how you can manage cookie settings:

    • Functional cookies – We use functional cookies to retain information you entered (such as your language or
      your geographic region) and collect information about how the ClouPlay Websites are used. We may use third-party
      technology to track and analyze usage information to improve how the ClouPlay Websites function, improve your
      browsing experience, provide more relevant communications, and track the performance of our advertisements.

To manage the use of functional cookies on the ClouPlay Websites, consult your individual browser settings for
cookies. You can also visit https://www.aboutcookies.org/ for more
information on managing cookies. Note that disabling these cookies may impact functionality when using the
ClouPlay Websites.

    • Advertising cookies – We or authorized third parties may use cookies to show you ads for our products that we
      think may interest you on any devices you may use. You may see advertisements for ClouPlay’s products on other
      websites or mobile applications on any of your devices. These cookies also help us manage and track the
      effectiveness of our marketing efforts.

To manage the use of advertising cookies on the ClouPlay Websites, consult your individual browser settings for
cookies. In addition, many ad networks have joined the Digital Advertising Alliance’s self-regulatory program to
provide a single opt-out tool at: http://www.aboutads.info and at the
European Interactive Digital Advertising Alliance (EDAA) website: http://youronlinechoices.eu. However, ClouPlay does not guarantee that
using these tools will prevent online behavioral tracking using cookies through our Websites.

At present, ClouPlay and our third-party Marketing Partners do not honor Do Not Track signals set by some
browsers. If you wish to avoid behavioral tracking by ad networks, please choose from the available methods for
doing so or refrain from using the ClouPlay Websites.

    • Social media buttons – The ClouPlay Websites use social media buttons, such as the Facebook “like” button, the
      “Tweet” button and other sharing functions (collectively, “Social Media Buttons”). Through the Social Media
      Buttons, you may have the option to post information about your activities on the ClouPlay Websites to your
      profile page on a third-party social media network and share with others within your network.

Cookies may be set by the respective social media networks to track your online activity. ClouPlay has no direct
control over the information that is collected by these third parties. Your interactions with Social Media
Buttons are governed by the privacy policies of the respective social media networks.

  1. Editing and deleting your Personal Information and preferences and opting out of communications and direct
    marketing.

You can review, correct, edit, or delete the information that you provided to us by sending us an e-mail request at
[email protected] Please note that we may need to verify your identity before
processing your request. You may elect to “opt out” of receiving direct marketing or being included in market
research information. You can opt out of receiving email communications by following the instructions through the
unsubscribe option in ClouPlay’s emails. You may also opt out at any time, edit your account information, or delete
your account entirely by sending an e-mail request to [email protected] (please
indicate “Opt Out” in the subject line).

New categories of communication and notification might be added to the Preferences page of the ClouPlay Community
Forum from time to time. You can opt out of receiving future communications from these new categories or you can
unsubscribe and block future messages by following instructions through the unsubscribe option in those messages.

If you are a ClouPlay Platform Account Owner, you will continue to receive certain communications pertaining to your
ClouPlay Platform account such as service announcements and administrative messages even if you opt out of marketing
communications from ClouPlay.

While we will try to comply with any request pertaining to your Personal Information in accordance with applicable
law, please be aware that we may not be able to fulfill requests pertaining to information already shared with third
parties. Some information may be retained on our systems for recordkeeping purposes, and some residual digital
information cannot be removed or changed.

  1. Disclosure of Personal Information to third parties

We do not sell, disclose, or share Personal Information about you with third parties except under the following
circumstances and for the following purposes:

    • When we have your permission to provide you with services you requested and to carry out your instructions.
    • When required by law to respond to subpoenas, court orders, or legal process by public authorities, including
      disclosures required by national security or law enforcement agencies.
    • When we need to establish or exercise our legal rights, or to defend against legal claims, or when we believe
      it is necessary to share information in order to investigate, prevent, or take action regarding illegal
      activities, data breaches, suspected fraud, situations involving potential threats to the physical safety of any
      person, violations of ClouPlay’s Terms of Use, or as otherwise
      required by law.
    • We may transfer your Personal Information if ClouPlay is acquired by or merged with another company, to ensure
      the continuity of our business and services. In such an event, ClouPlay will make a public announcement before
      information about you becomes subject to a different privacy policy.
    • When we conduct joint webinars or marketing events with business partners, we may share participant contact
      information with such business partners for their marketing use.
    • We may share your Personal Information with third-party service providers or vendors that we engage to support
      ClouPlay’s business and/or the ClouPlay Websites. Examples include providers of website hosting services, website
      analytics services, and marketing and communication services. These third parties are authorized to process your
      Personal Information solely for the purposes of providing the relevant services to ClouPlay.

ClouPlay and its affiliates are located in different regions around the world, and ClouPlay works with strategic
partners across different industries, categories of business, and in different jurisdictions. By accessing the
ClouPlay Websites, your information may be transferred outside of your local jurisdiction.

  1. Retention of information

We may retain your information (including Personal Information) for any lawfully permitted period of time, and as
necessary to comply with our legal and contractual obligations, enforce our agreements, and enable us to investigate
events and resolve disputes.

  1. ClouPlay blogs and discussion forums

If you participate in a ClouPlay blog, discussion forum, or other parts of our Websites that allow you to post your
comments, you should be aware that the information you provide there may be made broadly available to others,
potentially inside and outside ClouPlay, who have access to that blog or discussion forum. Blogs and discussion
forums are monitored by ClouPlay, and we reserve the right to remove your content at our discretion. Each
participant’s opinion on a blog or discussion forum is his or her own.

  1. Third-party sites

The ClouPlay Websites include links to other websites owned or operated by third parties, such as our channel
partners who provide products and services that can be used together with ClouPlay’s products and services. ClouPlay
is not responsible for the privacy or security practices of any third-party websites, which are governed by their
own privacy policies.

  1. Confidentiality, security, and data integrity

We take great precautions to protect the integrity of your Personal Information. However, no data transmission over
the Internet or any other network can be guaranteed to be 100% secure. While we strive to protect information
transmitted on or through our Websites, we cannot and do not guarantee the security of any information you transmit.

To learn more about security, including the security measures we have taken and steps you can take to enhance the
security of your information when using the ClouPlay Websites, please contact us at [email protected]

  1. Rights of California Residents under the California Consumer Privacy Act of 2018 (CCPA)

If you are a resident of the State of California in the United States, you are entitled to certain rights under the
California Consumer Privacy Act of 2018 (CCPA). The categories of Personal Information we collect about or from you
are described in section 3 above, and the business purposes for which we collect such Personal Information are
described in section 4 above.

As a business subject to the CCPA, ClouPlay does not sell Personal Information. ClouPlay may share Personal
Information with third-party service providers or business partners for our own business purposes as described in
section 8 above. However, we disclose your Personal Information to these third parties only where you have consented
to disclosure of Personal Information to such third parties or where such third parties have agreed to contractual
limitations around their use, retention, and disclosure of Personal Information.

As a resident of the State of California, you have the following rights under the CCPA:

    • You have the right to request access to the Personal Information we collect from or about you.
    • You have the right to request details about how we process or disclose your Personal Information.
    • You have the right to request that we delete the Personal Information we have collected about you, subject to
      certain exceptions.
    • You have the right to not be denied any goods or services for exercising your rights under the CCPA.

To exercise any of these rights, you may contact ClouPlay by following the instructions in section 16 below. We may
need to verify your identity before we are able to process your requests.

  1. Rights of European Data Subjects under the General Data Protection Regulation (GDPR)

If you are in one of the EU/EEA countries, you are entitled to certain rights under the General Data Protection
Regulation (GDPR) EU Regulation 2016/679 and applicable national data protection regulations.

By visiting the ClouPlay Websites or communicating with ClouPlay, you acknowledge that we may process your Personal
Information for the purposes described above, either on the basis of your consent or if we have other lawful grounds
to do so. Under the GDPR, you have the following rights with respect to your Personal Information:

    • You have the right to withdraw consent to processing, where consent is the basis of processing. For the
      Personal Information we collect on the ClouPlay Websites, this means you may withdraw your consent to processing
      by leaving the ClouPlay Websites, suspending your account if you have registered on our Websites, and requesting
      that we delete your Personal Information by contacting us at [email protected]
    • You have the right to access your Personal Information that we hold and request further details about how we
      process it, under certain conditions.
    • You have the right to demand rectification of inaccurate Personal Information about you. We will promptly
      correct any information found to be incorrect.
    • You have the right to object to unlawful data processing under certain conditions.
    • You have the right to erasure of past data about you (your “right to be forgotten”) under certain conditions.
    • You have the right to demand that we restrict processing of your Personal Information, under certain
      conditions, if you believe we have exceeded the legitimate basis for processing, processing is no longer
      necessary, or if you believe your Personal Information is inaccurate.
    • You have the right to data portability of Personal Information concerning you that you provided us in a
      structured, commonly used, and machine-readable format, subject to certain conditions.
    • The Personal Information we collect on the ClouPlay Websites is not used for automated decision making and
      profiling, except for automated processes in the context of marketing. As stated above, you can opt-out of
      direct marketing by ClouPlay by contacting ClouPlay directly or by following the instructions through the
      unsubscribe options in our email messages.
  1. Cross-border Personal Information transfers and the EU-US Privacy Shield

ClouPlay is a global organization headquartered in the United States and has legal entities, business functions, and
systems in countries around the world.

We may share your Personal Information within ClouPlay and transfer it to countries in the world where we do
business, including outside of the EU/EEA and Switzerland. Other countries have privacy laws that are different from
privacy laws in your country. Regardless of location, ClouPlay handles Personal Information as described here, and we
take care to ensure that our employees, agents and strategic partners in other countries act in a manner consistent
with this privacy notice.

ClouPlay complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set
forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union and Switzerland to the United States, respectively.  ClouPlay has certified to
the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the
terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn
more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

If you are in the European Union, you have a right to access your Personal Information. If you wish to access your
information held by ClouPlay, please follow the contact information at the end of this notice.

ClouPlay may be liable for onward transfers to third parties in violation of the Privacy Shield Principles.

We will investigate and attempt to resolve requests, complaints, and disputes regarding use and disclosure of your
information in accordance with this Privacy Notice and may require further information from you in order to identify
you and to address the matter at issue.

People in the European Union, EEA, and Switzerland may submit unresolved complaints to binding arbitration in front
of the American Arbitration Association (“AAA”) under certain conditions. Information about AAA services can be
found at its website: http://go.adr.org/privacyshield.html. The
exclusive location for such arbitration shall be New York, NY, United States.

ClouPlay is subject to the regulatory authority of the U.S. Federal Trade Commission. The Federal Trade Commission
may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
Email: [email protected]
www.ftc.gov

  1. Contacting ClouPlay about this Privacy Notice

Any inquiries, concerns, or requests regarding the use or disclosure of your Personal Information should be directed
to ClouPlay’s data protection officer at: [email protected]

You may also send inquiries to the following address:

ClouPlay, Inc.
Istanbul Technical University
Arı Teknokent Arı 8 Kat:1 Sarıyer
Istanbul-Turkey

Changes to this Privacy Notice

ClouPlay may update this Privacy Notice at any time without prior notice. Any such changes will become effective
prospectively from the date of publication. This Privacy Notice was last updated on January 1, 2020. We encourage
you to check this page frequently for any changes to our Privacy Policy.

 

Privacy Notice for the ClouPlay Platform

This privacy notice explains how ClouPlay, Inc. (“ClouPlay”) collects, uses, processes, protects, and
discloses information on the ClouPlay Platform.

Please visit the Terms of Use for further conditions governing your use of
the ClouPlay Websites.

  1. What this Privacy Notice covers

This policy describes how ClouPlay handles Personal Information on the ClouPlay Platform.

For our privacy notice on information related to the ClouPlay Websites and other communications with ClouPlay go
to: Privacy Notice for the ClouPlay Websites

In this policy, “you” means any User that is authorized to use the ClouPlay Platform through an
Account Owner’s account; “we” or “us” means ClouPlay, including our subsidiaries
and affiliates.

Account Owner” the means the individual(s) or organization(s) that have permission to use the
ClouPlay Platform and/or ClouPlay products to provide services and distribute media from their account.

ClouPlay Platform” means the cloud-based hosted services, APIs, plug-ins, applications, media
players, custom websites, and storage provided by ClouPlay to Account Owners.

Partner” means trusted third parties and business associates that provide us with some of the
services that we provide to you. For example, our Partners include content distribution networks (CDNs), third-party
platforms that are integrated with the ClouPlay Platform via APIs or plug-ins, and third-party services you can
access through the ClouPlay Platform.

Personal Information” is information about you that is personally identifiable by name or can be
linked to you through a personal identifier like your address, e-mail address, phone number, or location, and which
is not otherwise publicly available. This definition is given here for the purpose of this notice only, and some
laws may use a different definition. If you are asserting your rights under law, the applicable legal definition
governs your rights.

Users” are those individuals (such as, customers, subscribers, viewers, employees, staff, faculty,
student, members, or other persons) who are authorized by an Account Owner to access video, audio, and/or other
content from their account.

  1. ClouPlay is a Data Processor

The ClouPlay Platform is a set of online hosted software (“SaaS”) tools for hosting, managing and distributing video
content over the Internet. We make accounts on the ClouPlay Platform available to Account Owners that are paying
customers, free trial users, and business partners. Information uploaded and stored on the ClouPlay platform is
associated with a given account. In each case, the Account Owner is the Data Controller of the Personal Information
of its Users on that account. ClouPlay is the Data Processor carrying out data processing activities and instructions
on behalf of each Data Controller.

  1. Disclosures of information under Account Owner control

Account Owners use the ClouPlay Platform to store, process, and distribute videos and other information belonging to
them or their Users through their websites, apps, or other comparable means. Depending on the configuration of the
ClouPlay Platform selected by the Account Owner, media and other information on the Account Owner’s account may be
viewable to the general public or to limited audiences. As the controller of Personal Information on the ClouPlay
Platform, our Account Owners are responsible for maintaining the privacy of Personal Information pertaining to their
Users.  ClouPlay is not responsible for disclosures of information made by Account Owners and their Users
through such Account Owners’ respective accounts. When we process your Personal Information on behalf of an
Account Owner, it is that Account Owner’s responsibility to protect your privacy.

If you are concerned about your privacy while interacting with services provided by a ClouPlay Account Owner, you
should address requests and inquiries relating to your Personal Information directly to that Account Owner. If you
contact us regarding information associated with an Account Owner’s account, we may forward your requests or
inquiries to the relevant Account Owner.

  1. When is your Personal Information collected on the ClouPlay Platform?

When you interact with the ClouPlay Platform through an Account Owner’s account, ClouPlay collects your Personal
Information. Examples of activities where you might interact with the ClouPlay Platform include:

    • Viewing videos on the Internet provided from a ClouPlay Platform account.
    • Uploading content to the ClouPlay Platform.
    • Appearing on videos hosted on the ClouPlay Platform.
    • Hosting and/or participating in live meetings or other forms of real-time communication through ClouPlay’s products.
    • Using applications connected to the ClouPlay Platform, logging in to applications connected to the ClouPlay
      Platform, or downloading a ClouPlay mobile application.
    • Interacting with the ClouPlay APIs.
    • Opening a free trial account or other partner account for the ClouPlay Platform or for individual ClouPlay products.
    • Downloading a ClouPlay application from sites like the Apple App Store and Google Play.
    • Interacting with ClouPlay on behalf of an Account Owner (for example, if you are an Account Owner’s account or
      business administrator or a technical contact you may provide your contact information to ClouPlay for service or
      billing purposes).

 

  1. What Personal Information do we collect about you on ClouPlay Platform accounts?

When you use the ClouPlay Platform as a User through an Account Owner’s account, the following categories of Personal
Information may be collected and processed:

  1. Information you upload or record– If you are authorized to upload videos to a ClouPlay account, record any
    real-time communication sessions initiated via the ClouPlay Platform or other ClouPlay products, or otherwise
    upload or distribute information via the ClouPlay Platform, such videos or information may potentially include
    Personal Information about you and/or other third parties.
  2. Your account activity– When you log in and interact with the ClouPlay Platform or products, we collect
    information about your account activity, such as the content you upload, the real-time communications that you
    host or participate in, your viewing history, your comments and chat history, etc.
  3. Information provided by the Account Owner– The Account Owner may enter or create Personal
    Information about you on its account. For example, your information may be included in the Account Owner’s
    authorized User lists, access permissions, or in audio or video content and/or metadata.
  4. Traffic information, instructions, and activity on the ClouPlay Platform – When you interact with the
    ClouPlay Platform, the system collects the traffic information needed to deliver your actions and instructions
    over the Internet. Personal Information about you may include IP addresses, and URLs used to deliver content to
    you, and the ClouPlay Platform may collect other system information such as MAC addresses to allow the system to
    recognize your devices. The ClouPlay Platform uses cookies to remember your preferences and/or support the use of
    digital rights management systems.
  5. Passwords and login credentials – When you log in to the ClouPlay Platform, we collect the user IDs
    and passwords used in order to access the ClouPlay Platform. When you log in to other Account Owner systems that
    are connected to the ClouPlay Platform (such as single sign-on systems or third-party portals), depending on the
    configuration of those systems, the ClouPlay Platform may receive user login credentials or an anonymous
    identifier or token.

Contact and billing information – If you are a ClouPlay Account Owner, we collect your contact and billing
information.

  1. How we use your Personal Information

We use your information solely for the following purposes:

    • Provide the services and functions you requested from the Account Owner and performing your actions and
      instructions on the ClouPlay Platform through the Account Owner’s account.
    • Providing support, service notices, billing, and other account-relevant information to Account Owners.
    • We use the Account Owner’s contact and billing address to send Account Owners offers and promotional
      information.
    • Creating aggregate statistics and analytics information for ClouPlay’s own use and our Account Owners’
      respective use.
    • We may use content on an Account Owner’s account to troubleshoot and resolve service issues on that Account
      Owner’s account.
    • We use traffic information and aggregated user information to better monitor the performance of the ClouPlay
      Platform, track account usage, and test and improve the ClouPlay Platform.
  1. Audit logs

The activity on the ClouPlay Platform production servers is logged within the system for the purpose of providing
ClouPlay Account Owners and Partners with statistical analysis of use, and to enable us to monitor the system,
perform security audits, track errors, report activity via the system, and to comply with data retention rules and
internal policies.

We use commercially reasonable methods to keep production logs secure and do not use them for any other purpose or
share them with third parties except for permitted disclosures to third parties as detailed below.

  1. Sharing information with Partners

We rely on certain trusted third-party Partners to provide part of the services and functions that make up the
ClouPlay Platform. For example, we transmit video content via third party content delivery networks (CDNs) and partner
with cloud infrastructure providers.

ClouPlay does not share your information, including Personal Information, with any third parties other than our
Partners except in the limited circumstances detailed below. Our Partners do not have permission to use your
Personal Information for any purpose other than to provide to ClouPlay the services we require to serve our Account
Owners.

The ClouPlay Platform is designed to interoperate with different systems.  Our Account Owners may choose to integrate
the ClouPlay Platform with their own systems or with other third-party services of their designation. Integration with
third-party services is solely at the Account Owner’s discretion. ClouPlay is not responsible for systems connected to
the ClouPlay Platform that are not under our control.

  1. Cookies and other activity tracking technologies

The ClouPlay Platform uses certain persistent first-party cookies to provide the best user experience and remember
your preferences on the ClouPlay Platform.

The ClouPlay Platform does not place third-party cookies on your devices. However, elements of the ClouPlay Platform,
such as the ClouPlay player may send information about your activities on the ClouPlay Platform to cookies placed by
others (such as ad networks) on your devices through web beacons, VAST tags, and other technologies. Other parties’
cookies are subject to their own privacy policies.

Most Internet browsers have options for controlling, disabling, and deleting cookies on your computer. To learn how
to control cookies using your browser settings, visit https://www.aboutcookies.org/. In addition, many ad networks have joined
the Digital Advertising Alliance’s self-regulatory program to provide a single opt-out tool at: http://www.aboutads.info and at the European Interactive Digital Advertising
Alliance (EDAA) website: http://youronlinechoices.eu. However, ClouPlay
does not guarantee that using these tools will prevent online behavioral tracking using cookies through the ClouPlay
Platform.

  1. Disclosure of Personal Information to third parties

Your Personal Information on a ClouPlay Platform account is controlled by the Account Owner. We do not disclose your
Personal Information to third parties except under the following circumstances and for the following purposes:

    • When we have the Account Owner’s permission, in order to provide the Account Owner with services it requests.
    • When required by law to respond to subpoenas, court orders, or legal process by public authorities, including
      disclosures required by national security or law enforcement agencies.
    • When we need to establish or exercise our legal rights, or to defend against legal claims, or when we believe
      it is necessary to share information in order to investigate, prevent, or take action regarding illegal
      activities, data breaches, suspected fraud, situations involving potential threats to the physical safety of any
      person, violations of ClouPlay’s Terms of Use, or as otherwise
      required by law.
    • If ClouPlay is acquired by or merged with another company, the ClouPlay Platform (including the information
      stored on Account Owner’s respective accounts) may be transferred to another entity.
    • With our Partners, as described above.
  1. Receipt of information from third parties

ClouPlay integrates with third-party services (e.g., Zoom, Webex, YouTube) to automate ingestion of media assets from
the third-party service to the ClouPlay Platform. Media assets ingested from third-party services and associated with
an Account Owner’s account are processed according to the same guidelines that apply to the Account Owner’s other
media assets and data stored on the ClouPlay Platform. Retention of media assets ingested from third-party services
is controlled by the Account Owner, who may choose to retain such media assets even after ending its relationship
with the third-party service.

Processing and retention of data from third-party services may also be subject to the privacy policies and terms
of use of those third-party services. In particular, ClouPlay’s YouTube integration uses the YouTube API Services.
Account Owners using ClouPlay’s YouTube integration agree to be bound by the YouTube Terms of Service (https://www.youtube.com/t/terms)
and are subject to Google’s Privacy Policy (http://www.google.com/policies/privacy). In addition
to ClouPlay’s normal procedures for managing and deleting the media assets, Account Owners can manage and revoke
the ClouPlay YouTube integration’s access to data via the Google security settings page at https://security.google.com/settings/security/permissions.

  1. Retention of information

We may retain your information (including Personal Information) on the ClouPlay Platform for any lawfully permitted
period of time, and as necessary to comply with our legal and contractual obligations, enforce our agreements, and
enable us to investigate events and resolve disputes.

  1. Confidentiality, security, and data integrity

We take great precautions to protect the integrity of your Personal Information. However, no data transmission over
the Internet or any other network can be guaranteed to be 100% secure. While we strive to protect information on the
ClouPlay Platform, we cannot and do not guarantee the security of any information you transmit.

To learn more about security, including the security measures we have taken and steps you can take to enhance the
security of your information when using the ClouPlay Platform, please contact us at  [email protected]

  1. Rights of California Residents under the California Consumer Privacy Act of 2018 (CCPA)

If you are a resident of the State of California in the United States, ClouPlay has certain obligations as a service
provider towards Account Owners regarding your Personal Information under the California Consumer Privacy Act of
2018 (CCPA). As a service provider, ClouPlay processes Personal Information solely for the purpose of providing the
services specified in the contracts between ClouPlay and the Account Owners. ClouPlay does not process Personal
Information collected through an Account Owner’s account for any other purpose.

If you are concerned about your privacy while interacting with services provided by a ClouPlay Account Owner, you
should address requests and inquiries relating to your Personal Information directly to that Account Owner. If you
contact us regarding information associated with an Account Owner’s account, we may forward your requests or
inquiries to the relevant Account Owner.

To learn more about your rights under the CCPA, you can visit the California Office of the Attorney General’s page
on the CCPA at: https://oag.ca.gov/privacy/ccpa.

  1. Rights of European Data Subjects under the General Data Protection Regulation (GDPR)

If you are in one of the EU/EEA countries, ClouPlay has certain obligations as a data processor towards Account
Owners regarding your Personal Information under the General Data Protection Regulation (GDPR).

 

The Account Owners, as data controllers, will be responsible for protecting your rights under the GDPR.

If you are concerned about your privacy while using service provided by a ClouPlay Account Owner, you should address
requests and inquiries relating to your Personal Information directly to that Account Owner. If you contact us
regarding information on an Account Owner’s account, we may forward your requests or inquiries to the relevant
Account Owner.

To learn more about your rights under the GDPR you can visit the European Commission’s page on Protection of
Personal Data, at: http://ec.europa.eu/justice/data-protection/index_en.htm.

  1. Cross-border Personal Information transfers and the EU-US Privacy Shield

The ClouPlay Platform hosts and processes information in the United States, and our staff accesses the ClouPlay
Platform in other countries where we conduct business operations.

ClouPlay complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set
forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information
transferred from the European Union and Switzerland to the United States, respectively.  ClouPlay has certified to
the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the
terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn
more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

If you are in the European Union, you have a right to access your Personal Information. If you wish to access your
information held on a ClouPlay Account, please contact the relevant Account Owner (the data controller).

The Account Owners, as data controllers, are responsible for your protecting your rights under the law applicable to
you.

ClouPlay may be liable for onward transfers to third parties in violation of the Privacy Shield Principles.

We will investigate and attempt to resolve requests, complaints and disputes regarding use and disclosure of your
information in accordance with this Privacy Notice which have not been resolved by the Account Owner. We may require
further information from you in order to identify you and address the matter at issue.

People in the European Union, EEA, and Switzerland may submit unresolved complaints to binding arbitration in front
of the American Arbitration Association (“AAA”) under certain conditions. Information about AAA services can be
found at its website: http://go.adr.org/privacyshield.html.  The
exclusive location for such arbitration shall be New York, NY, United States.

ClouPlay is subject to the regulatory authority of the U.S. Federal Trade Commission. The Federal Trade Commission
may be contacted at the following address:

Federal Trade Commission
Attn: Consumer Response Center
600 Pennsylvania Avenue NW
Washington, DC 20580
Email: [email protected]
www.ftc.gov

  1. Contacting ClouPlay about this Privacy Notice

Any inquiries, concerns, or requests regarding the use or disclosure of your Personal Information should be directed
to ClouPlay’s data protection officer at: İ[email protected]

You may also send inquiries to the following address:
ClouPlay, Inc.
250 Park Avenue South, 10th Floor
New York, NY 10003
Attention: Legal Counsel

  1. Changes to this Privacy Notice

ClouPlay may update this Privacy Notice at any time without prior notice. Any such changes will become effective
prospectively from the date of publication. This Privacy Notice was last updated on April 6, 2020. We encourage
you to check this page frequently for any changes to our Privacy Policy.

 

 

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