Privacy Policy

 

Privacy Policy

JOTT TV Limited (trading as Jewzy), a UK registered company, provides a streaming service internationally. You are accessing this website or app directly or through a link from the Jewzy OTT subscription service and consent to this Privacy Policy and Jewzy’s Terms of Use.

If you access our platform through our third party OTT platform provider, Vimeo (VHX Corporation), you are also referred to and bound by the Vimeo Terms of Use, Vimeo privacy and cookie policies for which Vimeo is responsible directly to you; any queries about the Vimeo Terms of use, privacy and other published policies should be directed to: ottsupport@vimeo.com. If you make any payment to Jewzy, it will be through our US third party payment supplier, Stripe, and you are referred to the Stripe privacy policy and terms of use. Please see further Contact Details below.

If you are not accessing the Jewzy Service through the Jewzy website, but instead through a third party app such as Apple or Roku, you are also referred to their terms of service and privacy policies.

This Privacy Policy applies to all Jewzy control and processing of Personal Data. It applies to anyone who visits its website or apps, including: prospective and registered subscribers to the Jewzy Service, including pre-sale, Pilot and other offers; Jewzy personnel; the personnel of Jewzy’s third party content providers and suppliers; crowd funding investors and donors.

By visiting or otherwise using our website or apps, you accept that you have read and agreed our online Privacy Policy.
This Privacy Policy was last updated on 18 August 2020.

Contents
  1. Introduction
  2. Data Controller; US contact; Data Protection Officer
  3. Purpose of the Processing and the Legal Basis for the Processing
  4. What categories of Personal Data we collect, how we collect and use (process) it and for what purpose(s)
  5. Your Rights
  6. Questions, Concerns and Complaint with a Supervisory Authority
  7. Disclosure of Personal Data
  8. Transferring Personal Data from the EU to the US
  9. Security of Personal Data
  10. Retention
  11. Terms of Use of this Website and Cookies
  12. Changes and Updates to this Privacy Policy
  13. Contacting Us
1. Introduction

We recognise the importance of protecting the privacy of Personal Data or personally identifiable information, being information which relates to an identifiable individual (“Personal Data”). We respect the rights of such individuals whose Personal Data we control and/or process and the obligations imposed by applicable law and are committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) (EU) 2016/679 (“GDPR”) and The Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 in relation to data processing, the ePrivacy Directive and other applicable law, (the “Data Protection Acts”) and Statutory Instrument 336 of 2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011. In so doing, our technical and organisational measures for the protection of Personal Data also reflect the requirements of the US Privacy Shield principles (though as a UK company we are not self-certified under Privacy Shield) and CCPA (California Consumer Privacy Act). Our third party suppliers (Vimeo and Stripe) are Privacy Shield and US law compliant. Where we transfer Personal Data from the UK to a third party supplier outside the EEA, it is pursuant to a data processing agreement and with your consent, as necessary to fulfill our contract with you or pursuant to appropriate standard clauses in compliance with GDPR.

The following Privacy Policy discloses what information we gather, how we use it, and how to correct or change it. We do not collect any information from anyone under 16 years of age. Our website, products and services are all directed to people who are at least 16 years old or older. We reserve the right, in our sole discretion, to modify, alter or update our Privacy Policy at any time. Such modifications, alterations, and updates shall be effective immediately upon posting. Your continued use of this website or app following the posting of a modified, altered, or updated Privacy Policy will mean you accept those modifications, alterations or updates.

2. Data Controller, US Office; DPO
2.1 Data Controller

When you contact us through the Jewzy website or app or contact Vimeo by way of a general enquiry or in order to find out more about subscription to Jewzy, you consent to our retention of your email address and name. You consent to us contacting you electronically for the purposes set out below, including responding to your queries and marketing latest offers and products and other Jewzy news. We shall hold this Personal Data as Data Controller in accordance with this Policy. Please note that the transmission of your Personal Data in response to the Contact Us form and contact by email will be unencrypted; you may unsubscribe at any time. Storage of your Personal Data will be encrypted. When you subscribe to Jewzy, including any Pilot or offer, you will be asked to provide additional details including payment details so that we can provide Jewzy to you, through our third party platform provider (Vimeo), using any applicable app provider (if you access the Service other than from our website) and using our payment processor (currently Stripe). We are Data Controller in respect of your Personal Data, but such third parties are processing your Personal Data on our behalf for you and you need to check their respective privacy policies and terms and conditions to which you consent. Vimeo is subject to our data processing agreement as required by law and for your protection.

Where you apply to or do join the Jewzy personnel team, or you are a member of the personnel team of a third party content provider or supplier, or invest or donate pursuant to our crowd funding sche
me, the Data Controller controlling the means of processing of your Personal Data and the purposes of such processing (subject to the circumstances in clause 2.4 below) is: JOTT TV Limited

Gable House, 239 Regents Park Road, London N3 3LF, England c/o PW; email: helpful@jewzy.tv

2.2 US Contact Details. If you are based in USA, you may either contact JEWZY as detailed above or contact Vimeo based in USA at ottsupport@vimeo.com VHX Corporation

555 West 18th Street
New York,
New York 10011

Attn: Legal Dept.

legal@vimeo.com

2.3 Data Protection Officer Jewzy’s data protection officer can be contacted as follows: legal@JEWZY.tv Tel: +44 208 933 0181, provide your name and contact details, ask for the DPO and specify your query.

3. Purpose of the Processing and the Legal Basis for the Processing
We gather two types of information when providing services or products to you (please also see para 4 below):

3.1 Personal Data This information will only be used by us in accordance with the terms herein, to enable us to contact you and discuss what subscription or products and/or other services we can provide to you now or in the future; we may contact you by way of direct marketing but shall enable you to opt out of this service at any time. The provision of your Personal Data is voluntary. However, if you do not provide us with the required Personal Data, we may not be able to provide you or your employer with the product/service requested and fulfil out contractual obligations to you.

3.1.1 Contact Us We collect information from you when you register on the Vimeo (or Apple/Roku or other platform) or our website or app or fill out a form.
When registering on the Vimeo/app or our website, through the “Contact Us” page or any other area where you may submit a request for subscription or other details, offer, newsletters / blogs or provide feedback, you may be asked to enter your name and email.

3.1.2 Subscription Services When you request a subscription, you will be asked to provide (in addition to your name and email address), your telephone number, postal address and, when the subscription requires payment, your credit card details. You may in additional be asked to provide other details necessary to fulfil our contractual obligations to you.

3.1.3 Jewzy Team and Jewzy Crowd funding. Where you provide your Personal Data to us as a prospective or current member of the Jewzy team, r as an investor or donor, this enables Jewzy to fulfil its contractual obligations to you and/or is necessary for legitimate purposes. Jewzy personnel will receive GDPR training and this Privacy Policy is an important part of that training.

3.1.4 Third Party Providers of Personal Data When you or your employer contracts with us in respect of one or more of the products, content and/or services which we offer on our own behalf or on behalf of our content partners, or where your employer is a supplier to Jewzy, you may be asked by that entity which provides the Personal Data on your behalf to us to read their privacy policy, since they will be your Data Controller. We use this information supplied by such third parties, so that we can fulfil our contractual obligations to them and provide to our partners and customers the goods and services, which we have contracted to provide. Your provision of this Personal Data will enable you and your employer to participate in features of the service and notify you about changes to the service. In any event, however, we require this Personal Data in order to be able to complete our contractual obligations to your employer.

3.2 Non-Personal Data: We may collect information about your visit to and use of this site, including sales data, traffic data and related site information. We may also collect anonymised information during the course of subscriptions which we provide. This information helps us to evaluate and improve our site and services and may also be used for investment analysis purposes. As Non-Personal Data does not personally identify you, we may use it for any purpose.


4. What Categories of Personal Data We collect, How We Collect and Use (process) it and for What Purpose(s)

4.1 Categories With a few exceptions, this information is limited to the kinds of information that are normally required when you subscribe to a television service: name and email; in addition, if you opt to take the chargeable subscription, we shall require your postal address, credit card and other details as necessary to supply the Service.

4.2 How We Collect It We collect your Personal Data as this Privacy Policy further describes when:
4.2.1 you use the Vimeo, third party app or our website, register as a user or we collect information from you with your consent.
4.2.2 you apply to join the Jewzy team or contract with us directly;
4.2.3 you become a donor (eg through our crowd funding page) or investor
4.2.4 when your employer contracts with us as a supplier or content provider

4.3 What We Use Your Personal Data For We collect information from you within our own system, which may be used as follows:

Purpose

Where you have contacted us or subscribed to the Jewzy Service and we are providing that service, we shall process and administer your Personal Data and process transactions, fulfil your requests, orders and/or to provide other information that you have requested. We require this Personal Data in order to be able to complete our contractual obligations to you and for legitimate purposes.
Retain subscription details for repeat orders and/or when you have opened an account with us and/or where you request us to do so We require this Personal Data in order to be able to complete our contractual obligations to you and for legitimate purposes.
Personalize your experience.
Improve our website and make the website easier for you to use. 
Our Cookie Policy applies.
Improve customer service.
To respond to your enquiries or comments submitted through our website and apps
Send periodic emails. You consent when you Contact Us through the Jewzy app or website or Vimeo/Apple/Roku/other platform or email us or you request such updates from Jewzy expressly.
Notify you about important news or blogs concerning our services, products, community updates, events, promotions and competitions, reports and other information. You consent when you Contact Us through the Jewzy app or website or Vimeo/Apple/Roku/other platform or provide consent or where you request such updates from Jewzy expressly.
Match Personal Data with third party data. Also, we may keep track of what portions of the website and app users are visiting and other user statistics, and aggregate this information to help us create a better experience for users of our website and app. This is all done in order to describe our products and services to prospective partners, advertisers, and other third parties, and for other lawful purposes. Our Cookie Policy applies.
Promote our offers, products and services on our website and third party partners’ websites
Provide you with information about offers, subscriptions, products and services that you request from us or, where you have consented to be contacted, for such purposes which we feel may interest you
To obtain your feedback
Create statistical reporting regarding our web activities. Our Cookie Policy refers.
In addition, in order to carry out our lawful activities and for legitimate purposes, we may collect and process your Personal Data to:

Allow you to use interactive features in our services
Retain a record of incoming and outgoing communications (e.g. email).

Direct Marketing. On occasion, we engage third parties to mail (hard copy or electronically) information to you, including items about subscriptions you may have purchased, or material from a community event. We have a legitimate interest in processing of Personal Data for direct marketing purposes. We may send postal marketing about a new offer. You may opt-out of this at any time by following the instructions in the marketing communication itself or by contacting us through Jewzy app or website or Vimeo (or Apple/Roku as the case may be).

In respect of our personnel resources, communications may be subject to automated monitoring to ensure that ours and our partners’ confidential information and Personal Data are protected as our GDPR policies provide and to detect breaches of security

Protect the security and integrity of the website, app and our services

Prevent and detect fraud or other prohibited or illegal activity

In response to a court order, request for cooperation from a law enforcement or other government agency

To permit applications for employment and contracts for services with us and related activities to such applications and contracts for service or services



To establish or exercise legal rights

To bring or defend legal claims

For responsible corporate governance or as otherwise required or permitted by applicable laws and/or regulations

In circumstances in which we believe disclosure is appropriate in connection with fraud prevention and prevention of other illegal, or unlawful activity or any other activity which is or may be contrary to our legal and regulatory compliance obligations

To protect and defend the rights, property or safety of Jewzy and/or other companies in the Jewzy group, its/their investors and other clients, staff, and/or service providers.

We continually strive to improve our services and the website and app offerings based on the information and feedback we receive from you. Your information helps us to respond more effectively to your requests and support your needs. Note: If at any time (other than in relation to current subscription or other contract) you would like to unsubscribe from receiving future communications, we include detailed unsubscribe instructions at the bottom of each communication.

5. Your Rights in respect of your Personal Data

This Privacy Notice is intended to provide you with information about what Personal Data Jewzy collects about you and how it is used. If you have any questions, please contact us at legal@JEWZY.tv or contact VIMEO if based in the USA.
If you wish to confirm that Jewzy is processing your Personal Data, or to have access to the Personal Data Jewzy may have about you, please contact us at legal@JEWZY.tv

You have various rights in respect of your Personal Data which can be summarised as follows:
  1. The right to be informed. Where Jewzy intends to collect your Personal Data, where this is not for fulfilling a contractual obligation owed by Jewzy to a deployment partner, you have a right to consent or object to such collection for the intended purposes. In respect of each intended purpose you will be asked to tick box to indicate your consent to each intended purpose for processing of your Personal Data
  2. The right of access. You may request to receive a copy of any Personal Data held by us, which personally identifies you. We may ask you to verify your identity and for more information about your request
  3. The right to rectification. We will correct or erase inaccuracies in the information we hold about you when we learn of the inaccuracy
  4. The right to erasure. Personal Data may be erased if we do not have a contractual or legitimate reason for retaining the information
  5. The right to restrict processing
  6. The right to data portability
  7. The right to object
  8. Rights in relation to automated decision making and profiling. Jewzy does not carry out any automated decision making

Please contact Jewzy in writing with any requests and provide verification that you are who you say that you are.

If you are an employee of one of our third party suppliers or content providers, we suggest that in the first instance you contact your employer who is a Data Controller.

If you are based in the USA, we suggest that in the first instance you contact our Third Party Platform provider, Vimeo (contact details above).

6. The Right to Lodge a Complaint with a Supervisory Authority

If you have a reason to complain about how your Personal Data has been controlled and processed by Jewzy, please in the first instance contact Jewzy and we shall endeavour to resolve your queries promptly. If you remain unsatisfied, you may lodge a complaint with:
Office of the Information Commissioner
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Phone: +44 303 123 1113 or 01625 545 745
Email: casework@ico.org.uk
Please copy any such communication to us so that we can work to resolve any outstanding issues promptly.


7. Disclosure of Personal Data
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the product or service requested or as this Privacy Policy provides.
We may disclose your Personal Data within the Jewzy group, to your employer with whom you are contracted (where applicable), professional advisers, and to such other third parties as may reasonably be required in connection with the purposes referred to in this Privacy Policy, such as operating our website and apps, arranging payments, conducting our business, marketing or servicing you, so long as those parties agree to keep this information confidential and take appropriate technical and organisational measures to keep your Personal Data safe. We reserve the right to disclose any and all pertinent information to law enforcement or other governmental officials as we, in our sole discretion, believe necessary or appropriate.

The disclosures of your Personal Data described in this Privacy Policy may, if you are (or your employer who passed us the Personal Data is) based outside the European Economic Area (EEA), involve the transfer, storage or processing of your Personal Data to such country, where the level of data protection is not as high as in the EEA. By providing us with your Personal Data in such circumstances you agree to such transfers of your Personal Data and accept that such transfers are necessary to enable us to fulfil our contractual obligations to you. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.

We may also disclose Personal Data in special cases when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Use, or may be causing injury to or interference with any of our rights or property, other users, or anyone else. We may disclose or access account information when we believe in good faith that the law requires it and for administrative and other purposes that we deem necessary to maintain, service, and improve our products and services.

8. Transferring Personal Data to the US or EU

The personal information Jewzy collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than as this Privacy Policy describes. However, you are referred in turn to each relevant third party platform (Vimeo), payment processor (currently Stripe) and app provider (eg Apple, Roku) privacy policy and terms and conditions, which shall apply in addition to Jewzy’s terms of use and this Privacy Policy

Where you have subscribed to our service and agreed payment, our third party platform provider and supplier of credit card services may be based outside the EU and may be in the United States. Where you are a subscriber (or respond to the Contact Us page and are) resident in the United States, the personal information Jewzy collects from you is stored in one or more databases hosted by third parties located in the United States and transferred to Jewzy or its subcontractors in the UK. These third parties do not use or have access to your personal information for any purpose other than as this Privacy Policy provides and/or pursuant to our agreement with you. Further, we use US based marketing automation platforms and email marketing/ postal services as a third party suppliers. The United States has not received a finding of “adequacy” from the European Union under Article 45 of the GDPR. For US subscribers and personnel, the Privacy Shield applies. For European and UK subscribers and personnel, Jewzy relies on your consent as this Privacy Policy provides and legitimate interests, since we are fulfilling our contract with you or direct marketing as GDPR permits or relying on derogations for specific situations as set forth in Article 49 of the GDPR and the third party suppliers’ Privacy Shield. In particular, Jewzy collects and transfers to the U.S. Personal Data only: with your consent; to perform a contract with you or your employer; or to fulfil a compelling legitimate interest of Jewzy in a manner that does not outweigh your rights and freedoms. Jewzy endeavours to apply suitable safeguards to protect the privacy and security of your Personal Data and to use it only consistent with your relationship with Jewzy and the practices described in this Privacy Policy. Jewzy also minimizes the risk to your rights and freedoms by not collecting or storing sensitive information about you.


9. Security of your Personal Data

To help protect the privacy of data and personally identifiable information processed by us, we maintain appropriate and proportionate physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your Personal Data to those Jewzy personnel who need to know that information to provide benefits or services to you. In addition, we train our personnel about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.

10. Retention Period

We shall retain and store your Personal Data securely and for as long as necessary in order to fulfil our contracts with you. We shall then only retain Personal Data for as long as necessary to comply with our legal obligations under relevant law and with regard to our legitimate interests. For more information on where and how long your Personal Data is stored, and for more information on your rights of erasure and portability, please contact the Jewzy’s data protection officer at legal@jewzy.tv

11. Terms of Use and Cookies

Please also visit our terms of use establishing the use, disclaimers, and limitations of liability governing the use of our website, apps and Vimeo platform at https://jewzy.tv.

As is true of most other websites and apps, the Jewzy website and apps collect certain information automatically and store it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of the Jewzy website and apps, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website and apps, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. The Jewzy website and apps also use cookies and web beacons. We do not track users when they cross to third party websites, nor provide targeted advertising yet; we shall obtain your express consent when targeted advertising is contemplated.

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information. Cookies make web-surfing easier for you by saving your preferences so that we can use the saved information to facilitate your use of our website and apps when you return to the site. The use of cookies is an industry standard, and as such, you will find that most major websites and apps use them.

We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
Please see our Cookie Policy For More Detail.

12. Changes to our Privacy Policy

If we decide to change our Privacy Policy, we will post those changes on this page on our website. We reserve the right to amend the Privacy Policy and Terms of Use at any time, for any reason, without notice to you, other than the posting of the amended Privacy Policy and Terms of Use at our website. We may communicate periodic reminders of our notices and terms and conditions and will communicate material changes thereto, but you should check our site frequently to see the current Privacy Policy and Terms of Use that is in effect and any changes that may have been made to it.

13. Contacting Us

If there are any questions regarding this Privacy Policy you may contact Vimeo (ideally, if in the USA) or us.

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