PRIVACY POLICY
[Last Modified: October, 2021]
This
Privacy Policy (“Privacy Policy”) governs the manner in which Stanis
Ltd. ("Company", "we", "us"
or "our") process, store and use the data collected from our
users which download, access and use our Media Player and the Services
therein (as such terms are defined under the End-User License Agreement (“EULA”)) ("you",
"your" or "User"). This Privacy Policy forms
an integral part of the EULA incorporated here by reference [https://www.stanis.tech/privacy].
Thus, any capitalized terms used herein but not defined herein, shall have the
meaning ascribed to them in the EULA.
This Privacy Policy explains what data
we may collect from you, how we process and use your data, including the way we
share it with others, and how you may exercise your rights related to your
Personal Data (as such term is defined below) under the following legislation:
(i) The EU General Data Protection
Regulation (“GDPR”), which shall apply to you in the event you are a
resident of the European Economic Area (“EEA”); and
(ii) The
California Consumer Privacy Act of 2018 ("CCPA") which shall
apply to you in the event you are a “California resident”, as such term is defined
under the CCPA.
If you choose to download or access
our Media Player, use our Services or otherwise provide data to us
Note, that we do not require you to
provide us with your Personal Data. However, some parts of our Media Player and
Services may require the processing of some of your Personal Data as shall be
explained in this Privacy Policy.
If
you have any questions or requests with respect to the processing of your
Personal Data or would like to contact us regarding this Privacy Policy, please
contact us via email at: [contact@stanis.tech].
1.
Policy Amendments
Except as
otherwise described herein, we may at our sole discretion and at any time amend
the terms of this Privacy Policy and at the very least, every 12 months if
required in accordance with applicable laws (such as the CCPA). Such changes
shall be effective upon the publication of the amended terms in this Privacy
Policy. Your continued use of the Service, following the amendment of the
Privacy Policy, constitutes your acknowledgment and consent of such amendments
to the Privacy Policy. The last revision will be reflected in the "Last modified"
heading above. In the event of a material change, we will
make our best effort to inform you of such changes, subject to the requirements
of and in accordance with any applicable laws. We recommend that you periodically review this
Privacy Policy so that you remain informed of any amendments that may have been
made. If you do not agree to the amended Privacy Policy, your sole and
exclusive option is to discontinue or terminate your use of the Media Player
and Service.
2.
The Data We Collect
2.1. “Non-Personal Data”, means an aggregated, non-identifiable, anonymized,
non-personal data, which may be made available or gathered via the User's
access and use of the Media Player and Service (“Non-Personal Data”),
including but not limited to, your aggregated usage and technical information
transmitted or automatically collected, such as, among other things, your
access time and date, and the scope, frequency, latency, what and when you view
through our Media Player and how you interact with media displayed through our
Media Player. For the avoidance of doubt, we are not aware of the identity of
the User from which the Non-Personal Data was collected.
The Non-Personal Data we collect is technical information that is
automatically transmitted by or from the User's device (for example, the type
of browser, the type of device used, technical information pertaining to the
User's device, language preferences, time stamps, clicks and pages visited,
search logs, the user's operating system, the User's internet service provider
and other similar information).
2.2. “Personal Data”, means individually identifiable data,
namely information that identifies an individual or entity or may with
reasonable effort identify an individual, including, but not limited to, first
and last name, phone number, email address, billing information, etc. Personal
Data may also include, Internet Protocol ("IP") address (the
addresses of computers on the Internet), and browsing data such as browsing
history. Personal Data shall mean Personal Information herein as well (as such
term is defined under the CCPA), for the purposes of the CCPA).
Personal
Data we collect from our Users:
|
Type of Personal Data we Collect |
Purpose
of Processing |
|
1.
Online Identifiers & Technical
Information When
you access
our Media Player and use our
Service, we
may,
either directly or indirectly through the use of cookies, collect certain identifiers such as
your IP address and your User ID. |
We use industry common practices to anonymize your IP address
immediately upon collection, and store it in its anonymized state (i.e., as
Non-Personal Data). We use this data for
our legitimate interests of (i) operating, providing,
maintaining, protecting, managing, customizing, and improving our
Media Player and the Services
therein, including the way in which we
offer them;
auditing and tracking usage statistics and traffic flow In the event required
under applicable laws, we will obtain your consent to gather such
information, for example through the use of cookies. |
|
2.
Contact Us & Customer Support: you
may be required to provide us with your contact information (such as your
name and email address), when you voluntarily contact us for support or other inquiries, either through sending us
a direct email, or by any other means of communication which may be made
available by us. |
We will use this information for
contacting you and responding to your inquiries, and providing you with the
support or information that you requested. Further, we may process
the contents of our correspondence with you, for our legitimate interest in improving our customer services, as well as
to resolve any disputes with you (if applicable). |
|
Search History The Media Player includes a search component that
will enhance your search settings. In order to provide this component, we will
collect your search history data. |
We will use
this information in order to provide you with our Media Player and the
Services therein in accordance with the performance of our contract. |
For the avoidance of doubt, in the event Non-Personal Data is
combined with Personal Data, we will treat it as Personal Data for as long as
it is combined.
Without derogating from our Users’
data protection rights as described herein, please note that before further
process your Personal Data for a purpose other than what we specifically
mentioned above, in case we intend to do so, we will provide you with
reasonable information regarding the revised purpose of processing.
In addition, we may use certain Personal Data as described above
in order to comply with legal requirements and under our legitimate interest of
preventing potentially prohibited or illegal activities, fraud,
misappropriation, infringements, identity thefts and any other misuse of the
Media Player or the Services and to enforce the terms of this Privacy Policy,
as well as to protect the security or integrity of our databases and the
Services, and to take precautions against legal liability.
If
the event the CCPA applies to you, below is a table specifying the categories
of Personal Information we have collected in the past twelve (12) months:
|
Category |
Examples |
Collected |
|
A. Identifiers. |
A real name, alias, postal address,
unique personal identifier, online identifier, Internet Protocol address,
email address, account name, social security number, driver's license number,
passport number, or other similar identifiers. |
Yes |
|
B. Personal information categories are listed
in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). |
A name, signature, social security
number, physical characteristics or description, address, telephone number,
passport number, driver's license or state identification card number,
insurance policy number, education, employment, employment history, bank
account number, credit card number, debit card number, or any other financial
information, medical information, or health insurance information. Some personal information included in
this category may overlap with other categories. |
No |
|
C. Protected classification
characteristics under California or federal law. |
Age (40 years or older), race, color,
ancestry, national origin, citizenship, religion or creed, marital status,
medical condition, physical or mental disability, sex (including gender, gender
identity, gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information). |
No |
|
D. Commercial information. |
Records of personal property, products
or services purchased, obtained, or considered, or other purchasing or
consuming histories or tendencies. |
No |
|
E. Biometric information. |
Genetic, physiological, behavioral, and
biological characteristics, or activity patterns used to extract a template
or other identifier or identifying information, such as fingerprints, facial
recognition, and voice, iris or retina scans, keystroke, gait, or other
physical patterns, and sleep, health, or exercise data. |
No |
|
F. Internet or other similar network
activity. |
Browsing history, search history,
information regarding a consumer's interaction with a website, application,
or advertisement. |
Yes |
|
G. Geolocation data. |
Physical location or movements. |
No |
|
H. Sensory data. |
Audio, electronic, visual, thermal,
olfactory, or similar information. |
No |
|
I. Professional or employment-related
information. |
Current or past job history or
performance evaluations. |
No |
|
J. Non-public education information
(per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g,
34 C.F.R. Part 99)). |
Education records directly related to a
student maintained by an educational institution or party acting on its
behalf, such as grades, transcripts, class lists, student schedules, student
identification codes, student financial information, or student disciplinary
records. |
No |
|
K. Inferences drawn from other personal
information. |
Profile reflecting a person's
preferences, characteristics, psychological trends, predispositions,
behavior, attitudes, intelligence, abilities, and aptitudes. |
No |
3.
How We May Collect Your Data?
We
may collect data as follows:
1.1. Automatically – we may use cookies or similar tracking technologies to
gather some information automatically.
1.2. Provided by you voluntarily – we
will collect information if and when you choose to provide us with the
information, such as your communications with us, all as detailed in this
Privacy Policy.
4.
With
Whom Do We Share Data?
We do not sell,
trade, or rent Users' Data to other parties, except as under the following circumstances:
1.1. Non-Personal Data. Non-Personal
Data, aggregate and statistical, or otherwise anonymized data may be shared
without limitation with third parties at our discretion. This information does
not contain Personal Data and is used to develop content and services for our
Users.
1.2. Personal Data. We may
share Personal Data only under the following limited circumstances:
·
To comply
with any applicable law or regulation (including our policies and agreements),
solely to the extent needed to establish or exercise our rights to defend
against legal claims or to prevent harm to the rights, property or safety of
us, our Users, yourself or any third party or for the purpose of collaborating
with law enforcement agencies or in case we find it necessary in order to
enforce intellectual property or other legal rights;
·
With trusted
partners and third parties who assist us in operating and providing the
Services and conducting our business, such as fraud prevention, marketing,
account maintenance and technology services. Please note that the Company uses
Bing search engine and some of the web search services provided to Users are
provided by our third party service provider - Trovi
Search and powered by Trovi search partners. For
information on the web search services data collection, please visit http://info.trovi.com/Privacy, and the
search provider's privacy policy, as applicable;
·
In the event
of a corporate transaction (e.g. sale of a substantial part of our business,
merger, consolidation or asset sale). In the event of the above, our affiliated
companies or acquiring company will assume the rights and obligations as
described in this Privacy Policy;
·
For the purpose
of operating our business and providing the Services, as well as to detect
fraud, security or technical issues in connection with the Service;
·
To enforce
the terms of this Privacy Policy and the terms of the EULA, including the
investigation of potential violations thereof, solely to the extent required;
and
·
Under your
explicit consent if you specifically request us to provide a third party with
your Personal Data (e.g. music interests and recommendations) or if you provide
us with your explicit approval to share your information before the disclosure.
As required under the CCPA, please see
below specific information regarding the disclosures of Personal Information for
a business purpose:
In the preceding twelve (12) months,
we have not disclosed any categories of Personal Data for a business purpose.
We may
disclose your Personal Data for a business purpose to the
following categories of third parties:
·
Service Providers;
and
·
Other third
parties (including advertisers, media networks and feed providers).
Personal Data disclosed by us for a
business purpose, is subject to contractual obligations on behalf of the service
provider to not use this data for any purpose except performing its obligations
under our engagement.
As required under the CCPA, please see
below specific information regarding the sale of Personal Information
In
the preceding twelve (12) months we have not sold Personal Data.
5.
User Rights
Applicable
data protection and privacy laws may provide you with the ability to exercise
some User rights regarding your Personal Data collected by the Company (which
might be different in each jurisdiction). If you are a resident of the EEA or
California, the provisions of the GDPR and the CCPA, respectively, may provide
you with some of the following rights: (i) The
right to be informed: in order to ensure fair and transparent
processing, you have the right to be provided with information regarding our data
collection and privacy practices, as detailed in this Privacy Policy; (ii)The right to access data: you have the right to receive
confirmation from us as to whether we process your Personal Data and in some
cases, be provided with a copy of the Personal Data that we process; (iii) Rectification: if you are an EEA
resident, you may request the rectification of your Personal Data that we
hold; (iv) The right to be forgotten: you may request the erasure
of your Personal Data that we hold if certain conditions are met for
example: (a) if the Personal Data is no longer needed for the original purpose
it was processed for and there is no new lawful basis for continued processing;
(b) if you have exercised your right to withdraw consent (if applicable), or to
object to the processing and we have no overriding grounds for continuing to
process the Personal Data; (c) the Personal Data is processed unlawfully; or
(d) the erasure of Personal Data is necessary in order to comply with
applicable legislation. This right is not absolute. We may reject your request
under certain circumstances, including a situation in which we must retain the
data in order to comply with legal obligations or defend against legal claims; (v) The right to restrict
processing: you may limit the purposes for which we process
your Personal Data, when: (a) the accuracy of the Personal Data is contested; (b)
the processing of the Personal Data is unlawful and you request that the
processing of such Personal Data be restricted instead of erased; (c) the
Personal Data is no longer needed for the original purpose it was collected,
however the data is still required to establish, exercise or defend legal
rights; or (d) there are overriding grounds in the context of an erasure request; (vi) The right to object:
you may object to the processing of your Personal Data by us,
in the event our basis for processing the Personal Data is our legitimate
interests, however, we will be permitted to continue the processing if our
legitimate interests override your rights, or when processing is necessary to
establish, exercise or defend a legal claim or right; (vii) Portability: you have
the right to have your Personal Data "ported" to a third-party
provided that: (a) the Personal Data was provided by you; (b)
the Personal Data is processed automatically; (c) and the Personal Data was
processed on the legal bases of contract or consent; (viii) Supervisory
Authority: you
may exercise your right to file a complaint to a supervisory authority in your
jurisdiction; (ix) Withdraw Consent: you have the right to
withdraw consent when consent is the legal basis for the processing of your
Personal Data; and (x) The Right to Non-Discrimination
(applicable only in the event you are California resident): you have the right
not to be discriminated against for having exercised your rights under
applicable law. Specifically, the business may not (amongst others): (a) deny
the consumer goods or services, (b) charge the consumer different prices for
goods or services, or (c) provide the consumer with a different quality of
goods or services whether by denying benefits or imposing penalties on the
consumer; and (xi) Do not sell (applicable only if you are a
resident of California): you have the right to direct businesses to stop
selling your Personal Data.
If you wish to exercise any or all of the
above rights, please download our data subject request form available at: stanis.tech/dsr and send it to our data protection
officer at: dpo@stanis.tech.
Subject to the applicable regulation,
where we are not able to provide you with the information for which you have
required, or to the extent you have required, whatever that reason might be, we
will endeavor to explain the reasoning for this and inform you of your rights. In the
event that you choose to make a data subject request, we may require additional
information from you in order to verify your identity and locate your data.
Furthermore, please note that the process of locating and deleting the data may
take up to one (1) month, unless otherwise required or permitted under
applicable law.
Data
privacy and related laws in your jurisdiction may provide you with different or
additional rights related to the data we collect from you, which may also apply.
Please
note that we may charge a small fee in order to fulfill your request, all in
accordance with applicable laws.
6.
Information Retention Policy
Unless we are
instructed otherwise by Users, we retain the data we collect for as long as
needed to provide the Service and to comply with our legal obligations, resolve
disputes and enforce our agreements. We will retain the data we collect for as
long as legally permissible, in accordance with applicable laws.
7.
Children Information
Our
Media Player is a general audience Player, which is not
directed to Users under
the age of 16. Hence, you
hereby represent and warrant that: (i) you are at
least 16 years of age; or if you are located in any other geographical location,
you are above the age defined as “child” under applicable laws in your
jurisdiction (collectively “Child” or “Children”); and (ii) you
are of legal competence to enter into this Privacy Policy. If you are under 18,
please be sure to read the terms of this Privacy Policy with your parents or
legal guardians. We do not knowingly collect or solicit information from children.
If we obtain actual knowledge that a User is considered to be a Child, we will
take steps to immediately delete such User’s Personal Data. If you become aware
or have any reason to believe that a Child has shared any information with us,
please contact us at: contact@stanis.tech
8.
Security
Your privacy is very important to the
Company and we are therefore committed to protecting your Personal Data from
unauthorized access, use or disclosure. Thus, we have implemented physical,
technical and administrative security measures for the Media Player and Services
that comply with applicable laws and industry standards. The Personal Data collected
by the Company is stored in the Google Big Query Cloud servers. For more
information regarding the data security provided by Google, please see: https://cloud.google.com/security/.
The Company aims to minimize the
amount of data that it stores on its servers in the first place. Please contact
us at: contact@stanis.tech , if you
feel that your privacy was not treated in accordance with this Privacy Policy
or if any person attempted to gain unauthorized access to your Personal Data.
We will make a reasonable effort to
notify you and the applicable authority (if required under the applicable laws)
in the event of a data incident in which we discover your Personal Data is at
risk.
9.
Transfer of Data
We may store or process your information in the United States or in other countries and the storage location might be different from the country from which you interacted with our Media Player and Services As such, we take all necessary steps in order to ensure that sufficient safeguards are provided during the transferring of your Personal Data and that your information receives an adequate level of data protection upon its transfer outside the EEA, and you may exercise your rights, where applicable, to receive information regarding the transfer mechanism that was used during such transfer. Personal Data transferred to countries outside the EEA will comply with the standard contractual clauses approved by the European Commission.
10.
Do Not Track Disclosure
Our Service does
not respond to Do Not Track signals. For more information about Do Not Track
signals, please see: http://www.allaboutdnt.com/.
11.
Contacting us
If you have any questions about this
Privacy Policy, or the practices of our Service, please contact us at contact@stanis.tech.
Data
protection officer:
Our data protection officer's contact details are: dpo@stanis.tech