SecureChannel Privacy Policy

Last modified: 08 September 2015
INTRODUCTION

We value your privacy. This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us.

The use of our services may involve the collection and use of your Information (as defined in the “The Information We Collect and How We Collect It” section below) on our services (including our website: www.sec-channel.com). It is important for you to understand how this happens and how you may control it, so please read this Privacy Policy carefully.

By using our services, you agree that we may collect, use and share your Information in accordance with this Privacy Policy, as revised from time to time.

If you wish to contact us regarding this Privacy Policy or any privacy-related matters, please contact our Support Team via email at support@securecom-media.com.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies across all of our services as defined above.

This Privacy Policy is incorporated into and form part of the SecureChannel Terms of Service that you have agreed to in order to use our services. Any terms used in this Privacy Policy will have the same meaning as the equivalent defined terms in the SecureChannel Terms of Service, unless otherwise defined in this Privacy Policy or the context requires otherwise.

Please also note that this Privacy Policy does not apply to Information collected: (i) through third party services (including any third party websites) that you may access through our services; or (ii) by other companies and organizations who advertise their services via SecureChannel.

CHANGES TO THIS PRIVACY POLICY

We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.

Where we consider that any changes to this Privacy Policy are reasonably material, we will notify you (via our website http://www.sec-channel.com), direct communication to you, or other means) prior to the change becoming effective. By continuing to use our services after any changes to this Privacy Policy, with or without notice from us, you are agreeing to the revised Privacy Policy.

THE INFORMATION WE COLLECT AND HOW WE COLLECT IT

In providing our services, we collect, store and use the following Information relating to you:

Information” is Personal Information and Non-Personal Information;

"Personal Information" is any information or combination of information that relates to you, and can be used to identify you. Personal Information may include the following:

• information you make available to us when you open an account or use our services, such as your name, telephone number and email address; • information which you make available to our services as you use them, including Shared Information you make available to others through our services and information you store using our services; • Shared Information that others using our services make available about you, such as information contained in posts they make and communications they make to you and others using our services; • information we collect as you use our services, such as certain Location Data and Log Data; • “Location Data” is information that we collect regarding your location (when you use a location-enabled service), including; • the location of your device when you use our services, such as from the GPS, WiFi, compass, accelerometer or other sensors in your mobile device; • the IP address of the device or internet service you use to access our services; • other information made available by you or others that gives an indication as to where you are or have been located, such as account information that indicates where you are located and Shared Information you or others post indicating your location, such as any geotag information that is embedded in any photos you make available to us; • if you have provided us with your location data previously and would like us to delete such existing location data, you may be able to do so via our services.

"Log Data" is technical information that is automatically collected by us when you use our services, whether through the use of cookies, web beacons and log files (as explained in more detail in the “Cookies, Web Beacons and Log Files” section below) or otherwise, including:

• technical information such as your mobile carrier, configuration information made available by your web browser or other programs you use to access our services, your IP address and your device’s version and identification number; • information about communications you have made using our services, such as the people you’ve communicated with and the time, data and duration of your communications; • metadata, which means information related to items you have made available through our services, such as the date, time or location that a shared photograph or video was taken or posted.

Non-Personal Information” is any information that relates to you but from which it is not practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymized form.

Shared Information” is information about you or relating to you that is voluntarily shared on our services, including postings that you make on our services (including your public profile, the lists you create), any postings from others that you re-post and including Location Data and Log Data associated with these postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using our services share about you.

HOW WE USE YOUR INFORMATION

We may use your Information for any of the following purposes:

• to provide our services to you; • for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services; • to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customization, personalized help and instructions, or other responses to your and other customers’ usage of our services; • to help us develop our new services and improve our existing services; • to allow you to participate in surveys about our products and services. If you participate in a survey, we may request certain personally identifiable information from you. Participation in these surveys is voluntary and you therefore have a choice whether or not to disclose this information. We use may use a third party service provider to conduct these surveys and such third party service provider will be prohibited from using your personally identifiable information for any other purpose.

Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through our site or service may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualized manner). You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available.

If any of your Personal Information comprises Your Content (as defined in the SecureChannel Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the “Your Content” section of the SecureChannel Terms of Service.

COOKIES, WEB BEACONS AND LOG FILES

When you access our website or use our services, we (including companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, "Flash cookies," or other local storage provided by your browser or associated applications (collectively "Cookies"). We use these technologies to recognize you as a customer; customize services, content; help ensure that your account security is not compromised; mitigate risk and prevent fraud; and to promote trust and safety across our website and services.

You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our website and services.

For more detailed information on our use of these technologies, please see our Cookies Policy below.

SHARING OF YOUR PERSONAL INFORMATION

Other than as permitted under this Privacy Policy or as otherwise consented to by you, we will not transfer your Personal Information to any other third parties for their processing for any purposes.

We and our affiliate companies may share your Personal Information within our group of companies and with joint venture partners and third party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assists us and you with location data), in each case, for the purposes of: (i) providing our services to you; (ii) assisting us in carrying out the purposes set out under the “How We Use Your Information” section above; (iii) carrying out our obligations and enforcing our rights under the SecureChannel Terms of Service or this Privacy Policy; and/or (iv) help understand and improve our services. These third parties may be located, and use and store your Personal Information, outside of your jurisdiction for these purposes.

Where we or our affiliate companies do share your Personal Information with any third parties, we will use reasonable efforts to ensure that such third parties only use your Personal Information: (i) in compliance with this Privacy Policy; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.

You consent to the third party use, sharing and transfer of your Personal Information (both inside and outside of your jurisdiction) as described in this section.

As we continue to develop our business, we or our affiliate companies may be acquired by a third party or re-organize our group structure. In these circumstances, it may be the case that your Information is transferred within our group and/or transferred to a third party who will continue to operate our services or similar services under either this Privacy Policy or a different privacy policy which will be notified to you. The party to which your Personal Information is transferred may be located, and use your Information, outside of your jurisdiction.

You agree that we or our affiliate companies may be required to retain, preserve or disclose your Personal Information: (i) in order to comply with applicable laws or regulations; (ii) in order to comply with a court order, subpoena or other legal process; (iii) in response to a request by a government authority, law enforcement agency or similar body (whether situated in your jurisdiction or elsewhere); or (iv) where we believe it is reasonably necessary to comply with applicable laws or regulations. You also agree that we or our affiliate companies may need to disclose your Personal Information in order to enforce the SecureChannel Terms of Service or this Privacy Policy, protect our rights, property or safety, or the rights, property or safety of our affiliate companies or other users of our services.

A WORD ABOUT SHARED INFORMATION

Please consider carefully what you post and communicate through our services. In most instances, you may control what access the wider public has to your Shared Information via the privacy settings in our services. However, there are still chances that Shared Information may be broadly and instantly transmitted (and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us). If you would like to update or amend your Personal Information you may do so by logging into your account and making the appropriate changes or by contacting our Support Team. To request removal of your Personal Information from our services, or to request the removal of an unauthorized account, please contact our Support Team. In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so.

COMMUNICATIONS FROM US

Newsletters and other types of communications

When you use our service, we may use your Information to send you emails, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Support Team via the contact information within this Policy.

Service-related announcements

We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend one of our services for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.

A WORD ABOUT SENSITIVE PERSONAL INFORMATION

In some jurisdictions, certain Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterized as “sensitive” and is subject to stricter regulation than other personal information. Please note that content and information that you input to our services, such as photographs or information about your school or social activities, may reveal your sensitive Personal Information to others.

We urge you to consider whether it is appropriate to communicate Personal Information of a sensitive nature in the manner you are proposing to communicate it using our services.

You consent to all processing of sensitive Personal Information for the purposes and in the manner described in this Privacy Policy.

Please note that we do not use your sensitive Personal Information for the purpose of serving advertising to you.

WHAT INFORMATION DO WE SHARE WITH THIRD PARTIES?

We will not share your Personal Information outside of SecureChannel or our controlled subsidiaries and affiliates except as described below:

• with other users who have permission to see your information based on information delivery rules and the preferences set in your account; • with service providers who are working with us in connection with the operation of our services (these service providers have access to your Personal Information only to perform services on our behalf and are obligated not to disclose it or use it for any other purposes); • we may share aggregated information and non-identifiable information with third parties for industry analysis, press, demographic profiling and other similar purposes; • to enforce or apply our privacy policy, our Terms of Service or our other policies or agreements.

We DO NOT share any of your information with 3rd party advertisers.

We are not responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties. Your use of any such third party, including any Personal Information you provide to such third parties, are subject to the relevant third party’s own terms of services and privacy policies and not the SecureChannel Terms of Service or this Privacy Policy, so please review their terms carefully. This Privacy Policy only applies to any Information collected by us, does not apply to any services offered by or information practices of any third parties, and we bear no liability for any third party use of any Information provided by you to them.

AGE RESTRICTIONS

To be eligible to use the Service, you must be at least 18 years old (or the applicable age of majority and contractual capacity if you reside in a jurisdiction where the age of majority or contractual capacity is above 18 years of age). By accessing or using the Service you represent and warrant that you are 18 or older. We do not knowingly collect Personal Information from any individuals under the age of 18. Please contact our Support Team if you believe we have any Personal Information from any individuals under the age of 18 and we will promptly investigate (and remove) such Personal Information.

TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION

We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction.

You consent to the transfer of your Personal Information (both inside and outside of your jurisdiction) for the purposes described in this Privacy Policy.

We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of Information.

In our service, we will use encryption technology (such as SSL) to protect certain sensitive Information (such as location data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. Our systems and the communications networks through which you access our services may be subject to security breaches and failures which are due to circumstances beyond our reasonable control. If you have any questions regarding the security of your Personal Information, please contact our Support Team.

PERIOD OF USE OF YOUR PERSONAL INFORMATION

Subject to applicable laws and regulations (including as set out under the “Sharing of your Personal Information” section above), we will only use your Personal Information for so long as is necessary to fulfil the purposes as set out under the “How We Use Your Information” section above.

Subject to applicable laws and regulations, you may have the right to request to receive a copy of and make any corrections to your Personal Information which we hold, and to request that we deactivate and not use any of your Personal Information that is stored by us. You may direct such request to our Support Team, or where we offer this option in our services, you may also log into your account with us and make the appropriate changes. We will respond to all requests made to our Support Team under this “Retention of your Personal Information” section within 60 days.

Should your account be terminated by you or us for any reason, we will (subject to the above paragraph) take steps to ensure that your Personal Information is no longer available through our services, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination. However, it is important to note that communications made by you using our services may put your Personal Information in the hands of third parties that we cannot control.

SecureChannel Cookies Policy

Last modified: 08 September 2015

We may, from time to time, use cookies, log files and web beacons (and other similar technologies) to collect, use and store Information about you or relating to you. This policy describes how we use such cookies, log files and web beacons.

Please note that we collect, use and store your Information in accordance with our SecureChannel Privacy Policy. This policy is incorporated into and form part of our SecureChannel Privacy Policy that you have agreed to in order to use our services. Any terms used in this policy will have the same meaning as the equivalent defined terms in our SecureChannel Privacy Policy.

WHAT IS A COOKIE AND WEB BEACON?

A cookie is a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content. Web beacons are electronic image files or other technologies that may be embedded within websites or emails that may be used to keep count of visitors, record when and if an email or website is viewed, or access certain cookies.

WHAT IS A LOG FILE?

We and our third party tracking-utility partners use log files to gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.

HOW DO WE USE COOKIES, LOG FILES AND WEB BEACONS?

We and our third party tracking-utility partners may from time to time gather certain Information automatically via such cookies and web beacons and store it as Log Data.

We use our own cookies and web beacons to personalize your experience on our services and for various other purposes, including:

• remembering you. For example, cookies and web beacons can help us identify you as a registered user of our services or keep the preferences or information that you have previously provided; • analyzing how you use our services. We can use cookies, log files and web beacons to understand what users are doing on our services, or which pages or sections are most popular;

Please note that we use our cookies, log files and web beacons for these purposes, but may make certain aggregated Non-Personal Information obtained through these cookies and web beacons available to other partners to analyze how you and others use our services.

It is important to note that third party cookies, log files and web beacons are subject to the relevant third party’s own privacy policies and not our Privacy Policy. We are not responsible for third party cookies or web beacons.

SPECIFIC TYPES OF COOKIES

We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser.

Your browser may enable you to block or manage cookies or web beacons. However, please remember that if you block cookies, we may not be able to provide you with the optimal experience through our services and some of our services may not function properly.

Category of cookies use Description
Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you.
Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities.
Functionality We use such cookies to perform and improve the functions of our services.
Analysis and Research We use such cookies to follow up and improve our services and provide us with reference data for research and development of new services or functions.