BROADCASTERS DATA PRIVACY NOTICE
Zori Europe s.r.o (collectively "we", or "the Company”) provides this Privacy Notice to explain our practices regarding the collection, use, transfer and other processing of certain personal data about the Broadcasters (“Broadcaster Data”), as described in more detail below.
Please note you are under a legal obligation to provide the Company with some of the Broadcaster Data (as specified below), whereas providing the remainder of the Broadcaster Data is subject to your own free will and consent and to your relationship with the Company.
This Privacy Notice applies to current and former Broadcasters.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
During your contractual relationship with the Company, it is routine for us to collect, process and store Broadcaster Data. Although not an exhaustive list, this will include:
- PERSONAL INFORMATION: including legal name and contact information (full name, home address, phone number), date of birth, government identification numbers (driver’s license), citizenship/residency, personal status, photos and other data collection permitted or required by local law;
- ADDITIONAL IDENTIFICATION INFORMATION: including any name (other than the Broadcaster's legal name) ever used by the Broadcaster, including the Broadcaster's maiden name, alias, nickname, stage name, or professional name; a legible hard copy or legible digitally scanned or other electronic copy of a hard copy of the identificationdocument examined and, if that document does not contain a recent and recognizable picture of the Broadcaster, a legible hard copy of a Picture Identification Card (as this term is defined below); a copy of the depiction (including live cams or advertising) and, where the depiction is published on an Internet computer site or service, a copy of any URL associated with the depiction. If no URL is associated with the depiction, the records shall include another uniquely identifying reference associated with the location of the depiction on the Internet; and for any Broadcaster in a depiction performed live on the Internet, a copy of the depiction with running-time sufficient to identify the performer in the depiction and to associate the performer with the records needed to confirm his or her age.
- PICTURE IDENTIFICATION CARD: including a document issued by either: (a) the United States, a US State government, or a political subdivision thereof, or a United States territory, that bears the photograph, the name of the individual identified, and the date of birth of the Broadcaster, and provides specific information sufficient for theissuing authority to confirm its validity, such as a passport, permanent resident card (commonly known as a “Green Card”), or employment authorization document issued by the United States, a driver's license or other form of identification issued by a State or the District of Columbia; or (b) a foreign government-issued equivalent of any ofthe documents listed above when the person who is the subject of the picture identification card is a non-U.S. citizen located outside the United States at the time of original production and the producer maintaining the required records, whether a U.S. citizen or non-U.S. citizen, is located outside the United States on the original productiondate. The picture identification card must be valid as of the original production date.
- PAYMENT INFORMATION: including bank information, garnishments and deductions, and other related information.
- PERFORMANCE AND TALENT INFORMATION: including qualifications, evaluations, developmental planning, security policy permissions, communication data and other talent management and team based assessments.
- APPLICATIONS/RECORDS: In addition, the Company collects and maintains different types of personal information, including the personal information contained in medical history questionnaires and evaluations.
III.SOURCE OF BROADCASTER DATA
We generally collect the Broadcaster Data directly from the Broadcasters. From time to time, the Company may receive personal information about the Broadcasters collected from third parties we do business with in the course of our business interactions, such as regulatory bodies.
In those circumstances, the Company will take reasonable steps to ensure that those third parties have represented to us that they have the right to disclose the Broadcaster Data to us. In other cases not currently anticipated, we will notify you of where the data came from unless you are already aware of this information.
IV.PURPOSES OF USE OF BROADCASTER DATA
The Company uses and otherwise processes Broadcaster Data to the extent necessary or appropriate for the following purposes:
- Administering and managing all aspects of our relationship, including, but not limited to finance, accounting and compensation management;
- Information technology support;
- Cyber security programs;
- Security reasons (including ensuring the security of company-held information), such as to detect fraudulent or illegal behaviour, including for the purpose of conducting security screenings;
- Compliance activities;
- Conducting a due diligence of the Company in the event of a third party contemplating the purchase or investment in the Company;
- Establishing, managing or terminating the our contractual relationship;
- Identifying and communicating with you;
- Complying with applicable laws, including judicial or administrative orders.
V.SHARING BROADCASTER DATA WITH THIRD PARTIES
The Company shares the Broadcaster Data, including as stated below:
- THIRD PARTY SERVICE PROVIDERS: We share personal data with third party service providers, for all the purposes listed above.
These third party service providers have access to Broadcaster Data as needed to perform their functions, but they are not permitted to use it for other purposes. The Company also seeks to (i) exercise appropriate due diligence in the selection of such service providers, and (ii) require via contract or otherwise that such service providersmaintain adequate technical and organizational security measures to safeguard the Broadcaster Data, and process the Broadcaster Data only as instructed by the Company.
- EXTERNAL ADVISORS – the Company also shares the Broadcaster Data with its external advisors (e.g., lawyers, accountants, and auditors), subject to confidentiality provisions and as necessary.
- REGULATORY BODIES: We also share personal data with certain regulatory bodies to meet local statutory requirements (e.g. tax authorities, regulatory registration bodies, etc.), such as with governmental agencies and regulators (including tax authorities), social organizations (including a social benefits agency), courts and other tribunals, and government authorities, to the extent permitted or required by applicable law;
- PREVENT FRAUD AND CRIMINAL ACTIVITIES, LEGAL REQUESTS AND INVESTIGATIONS: We sometime disclose data when such disclosure is deemed necessary by the Company to detect or prevent criminal activities or fraud, to comply with any statute, law, rule or regulation of any governmental authority or any order of any court ofcompetent jurisdiction.
- BUSINESS TRANSFERS: As we continue to develop our business, we might sell or buy companies, subsidiaries, or business units. If the Company organizes its activities with another entity or in the event of a corporate transaction (such as in the sale of a substantial part of our business, merger, consolidation or asset sale), the Company shallhave the right to transfer to such entity the Broadcaster Data, provided that the other entity confirms that it shall be bound by the provisions of this Privacy Notice;
- LEGAL DISPUTES – If the Company receives a notice of legal proceedings against it, in the context of any dispute, claim, suit, demand or legal proceedings, if any, between the Company and you.
VI.SAFEGUARDING PERSONAL INFORMATION
The Company takes great care in implementing and maintaining the security of your personal data. To ensure the safety of our users’ information, and prevent unauthorized use of any such information the Company employs industry standard practices and procedures such as compliance checks to ensure the policy is being adhered, data protection impact assessments, internal audits of processing activities etc.
- within the human resources, legal, finance and accounting, security, communications, and information technology departments will receive access to Broadcaster Data when necessary in connection with their job responsibilities, and subject to the Company's internal security framework.
As an additional safeguard to, the Company employs a Data Protection Officer ("DPO"). The DPO has the power to insist on company resources for data protection matters and has as a deep knowledge of data protection regulation and law privacy requirements. The DPO's responsibility includes, among other things: privacy and security compliance advice, notify authorities of a data breach incident, conducting awareness and training programs, etc. The DPO's contact information is listed below.
VII.INTERNATIONAL TRANSFERS OF BROADCASTER DATA
Since the Company operates globally, it may be required to transfer Broadcaster Data to service providers and affiliates in jurisdictions that outside the European Economic Area (“EEA”).
These service providers and affiliates may use Broadcaster Data for the purposes described in Section III, including supporting payment processing, finance, accounting and human resources, global directory, and corporate compliance activities. The Company is taking ongoing measures to ensure that such service providers and affiliates have implemented appropriate safeguards to protect the security of Broadcaster Data.
The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Broadcaster Data and that such transfer is in accordance with EU privacy and data protection regulations. If you want to learn more about the details of these safeguards you should get in touch with us using the contact details at the bottom of this notice.
This section addresses certain rights you may exercise with respect to your Broadcaster Data. You can get more information in relation to your rights using the contact details below.
Right of access
You have the right to access the information we hold about you, including supplementary information about your Broadcaster Data.
Correcting or erasing your information
You have the right to ask us (and third parties to whom we transfer your personal information) to rectify your personal information if it becomes inaccurate or incomplete.
In addition, note that you are responsible to update the Company if there are any changes or inaccuracies in your Broadcaster Data.
You may also have the right to have incomplete personal data completed, including by means of providing a supplementary statement. Whether or not this is appropriate in any particular case depends on the purposes for which your information is being processed.
You have the right to ask us to erase your personal information if:
- your personal information has been processed unlawfully by us; or
- your personal information is no longer necessary for the purposes for which it was collected by us;
- or where you object to processing (see below) and there is no overriding legitimate interest for continuing to process your personal data.
We need to notify any third parties with whom we have shared your information that you have made a rectification or erasure requests. We will take reasonable steps to do this, but this may not always be possible or may involve disproportionate effort.
Restricting processing of your information
You have the right to restrict our processing of your personal information if:
- you contest the accuracy of the personal information held by us (for a period enabling us to verify the accuracy of the data);
- our processing activities are unlawful; or
- we no longer need your personal information but you would like us to retain it to ensure its continued availability to you in connection with any legal claims.
Right to object to processing
You can object to our processing your personal data under certain circumstances including where processing takes place in line with the Company’s legitimate business interests as set out above. Where you object to processing, we must stop processing your personal data unless we can show that our legitimate ground for processing of your personal data overrides your interests or where we need to process the data to establish, exercise or defend legal claims.
You have rights to obtain and reuse your personal data for your own purposes. This right only applies:
- to personal information you have provided to us (i.e. not any other information);
- where the processing is based on your consent or for the performance of a contract; and
- when processing is carried out by automated means.
We can refuse your data portability request if the processing does not satisfy the above criteria. Also, if the personal information concerns more than one individual, we may not be able to transfer this to you if doing so would prejudice that person’s rights.
You are able to submit a complaint to the applicable supervisory authority in relation to our processing of your personal data. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve this.
Kindly note that the above rights are not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse your request, for example, refuse your request where we need to process the data to exercise or defend legal claims. In addition, in certain instances, your Broadcaster Data may have been destroyed,erased or made anonymous in accordance with our record retention obligations and practices.
IX.RETENTION OF BROADCASTER DATA
Except as otherwise permitted or required by applicable law or regulatory requirements, the Company endeavors to retain your Broadcaster Data only for as long as it believes is necessary to fulfill the purposes for which the Broadcaster Data was collected (including, for the purpose of meeting any legal, accounting or other reporting requirementsor obligations), and as required under applicable laws and regulations. We may, instead of destroying or erasing your Broadcaster Data, make it anonymous such that it cannot be associated with or tracked back to you.
XI.HOW TO CONTACT US
If you have any general questions about the Services or the information that we collect about you and how we use it, please contact us via email at [email protected] or by sending a letter to:
- Zori Europe s.r.o,
- Attn: Data Protection Officer
- Na Folimance 2155/15, Vinohrady, 120 00 Praha 2
We will make an effort to reply within a reasonable timeframe. Please feel free to reach out to us at any time. If you are unsatisfied with our response, you can reach out to the applicable data protection supervisory authority.