Last Modified: February 27, 2024
Introduction
Aylo Social Ltd (hereinafter “we”, “us”, or “our”) operates the website https://www.uviu.com/ (hereinafter “UVIU”) and is the controller of the information collected or provided via UVIU.
Please read this Privacy Notice carefully, as your access to and use of UVIU signifies that you have read, understand, and agree to all terms within this Privacy Notice. We respect your privacy and are committed to protecting your Personal Information.
If you have any questions about our privacy practices, please see the section “Contact Information” below for information on how to contact us.
Scope
For the purposes of this Privacy Notice, “process”, “processed”, or “processing” means any operation or set of operations performed on personal data or on sets of personal information or data (excluding disclosure thereof) as defined hereinafter, by automated means, including one or several of the following operations: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, alignment or combination, restriction, erasure or destruction. Information on disclosure of personal data or of sets of personal data or personal information as defined hereinafter may be found in the “Disclosure of Your Personal Information” section below.
This Privacy Notice applies to information we collect:
It does not apply to information collected by:
The Data We Process About You
Personal data, or personal information, means any information about an individual from which that person can be identified by (“Personal Information”). It does not include data that has been anonymized or pseudonymized.
We may, depending on whether if you are a model, unregistered user, or a registered user on UVIU, we will process, collect, use, store and transfer different kinds of Personal Information about you, which we have grouped together as follows:
Biometric Information
We employ third-party service providers to verify your identity, age, and to verify the authenticity the identification documents you provide us using facial recognition technology. Facial recognition technology creates a mathematical representation of your facial features which are detected from the live scan of your face, your selfie, and the government-issued ID you submit or have previously submitted to us. Information derived from this mathematical representation, which may be considered biometric information under the laws of certain states and countries, is shared by our service providers with us. Your biometric information will be collected and processed to:
You will be asked to provide your consent to biometric information processing which you may withdraw at any time by using the links below. Withdrawing your consent will not affect the lawfulness of any collection, use, processing, or disclosure that occurred prior to the withdrawal.
Please note that this section entitled “Biometric Information” applies to relevant Models who wish to create an account and upload content but does not apply to identifiers processed by our third-party age verification service providers solely for the purpose of granting you access to UVIU in some states or countries.
How is Your Personal Information Collected?
We use different methods to collect data from and about you including through:
Model Contributions
We may provide areas on UVIU where you can post information about yourself and others and communicate with others, upload content (e.g., pictures, videos, audio files, etc.), and post comments or reviews of content found on UVIU. Such postings are governed by our Terms of Service. If you use a forum, blog, user commenting feature, community or other interactive sharing or social features that may be offered through UVIU, you should be aware that any Personal Information you submit, display, or publish there is considered publicly available and can be read, collected, used, and disclosed by other users of those features, by us, and other third parties without restriction, except to the extent limited access features are available, if any. In addition, such postings may appear on other websites or when searches are executed on the subject of your posting. If you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your Personal Information. Once you have posted information, you may not be able to edit or delete such information. To request removal of your personal information from our blog, sharing service or community forum, for example, send us an e-mail at privacy@uviu.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
User Contributions
When you use UVIU and follow models or subscribe to their content, we provide areas where you can comment on a purchased video, send a message to a model, add a model to your favorite list and subscribe to their content. Some features like comments on video are publicly accessible. We cannot control who sees those comments, so we encourage you to refrain from posting Personal Information in those areas. To request removal of your Personal Information from UVIU, you can send us an e-mail at privacy@uviu.com.
Cookies and Automatic Data Collection Technologies
As you navigate through and interact with UVIU, we use automatic data collection technologies to collect website activity data. The technologies we use for this automatic data collection may include use of cookies, which are small text files that are stored in your web browser or downloaded to your device when you visit a website.
We currently use the following types of cookies, which are set by UVIU:
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics. We use Google as a service provider to collect and analyze information about how users use UVIU, including by collecting website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will use the information only to provide Google Analytics services to us and will not use this information for other purposes. In addition, UVIU uses Google Signals, which are also services provided by Google that help us to run remarketing campaigns, collect more accurate data, and understand in a better way how users engage with UVIU on different devices (cross-device activity). Google Signals apply to Google users who accept personalized advertising on their Google accounts. The information collected by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU and the adequacy decision of the EU Commission C (2023)4745 confirming an adequate level of data protection in the US under the EU-US Data Privacy Framework and applicable national extensions (for example the UK Extension to the EU-US Data Privacy Framework). You can learn more on how Google uses data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
Third-party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on UVIU are provided or served by third parties. These third parties may use cookies alone or in conjunction with other tracking technologies to collect information about you when you click to view, access, or use any of the third-party feature on UVIU or directed to such third-party website. Unless expressly stated otherwise, UVIU does not provide any personal information to these third parties, however, when you click on a third-party internet-based advertising, they may collect information, including your IP address, advertisements you click, time zone setting and location, and information about your browser, operating system, and devices you use to access UVIU to provide targeted content.
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Choices About How We Collect, Use and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of UVIU.
How We Use Your Personal Information
We will only use your Personal Information when the applicable local law allows us to. Most commonly, we will use your Personal Information in the following circumstances:
Note that we may process your Personal Information on more than one lawful ground depending on the specific purpose for which we are using your data.
Purposes for Which We Use Your Personal Information
In general, we use information that we collect about you or that you provide to us, including Personal Information, for following purposes:
Disclosure of Your Personal Information
We disclose your Personal Information to and for the following purposes:
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We also may share aggregated information with third parties for conducting general business analysis. This information does not contain any Personal Information and may be used to develop content and services that we hope you and other users will find of interest and to target content and advertising.
For more information on recipients of Personal Information, please contact us by using the information in the Section Contact Information below.
Our Legal Bases under Canadian and European Union (EU) Privacy Law
To the extent required by applicable law, we rely on several lawful bases to use your data in these ways. This means we process your Personal Information only where:
Depending on the circumstances, we may rely on different legal bases when processing your same information for different purposes. If you reside outside the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”), the legal bases on which we rely may differ from those listed above.
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using UVIU you consent to the transfer of information that we process about you, including Personal Information, to other countries in which we, members of our corporate group (affiliates and related entities) or service providers are located. When we transfer Personal Information to countries outside of the EEA or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws.
Where available, we rely on decisions of the European Commission, known as “adequacy decisions”, recognizing that certain countries offer a level of protection of your Personal Information that is essentially equivalent to the EEA. In other situations, we rely on standard contractual clauses approved by the European Commission (and the equivalent standard contractual clauses for the UK, where appropriate) or on derogations provided for under the applicable law to transfer information to a third country.
For more information or to obtain a copy of our standard contractual clauses, please see the section “Contact Information” below on how to contact us.
Retention of Personal Information
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. Unless we have a legal obligation or a preservation or court order which would legally oblige us to retain your Personal Information for a specific period, where we no longer need to process and retain your Personal Information in accordance with this Privacy Notice, we will delete your Personal Information from our systems.
Where permissible, we will also delete your Personal Information upon your request. Information on how to make a deletion request can be found under “Your Rights Related to Your Personal Information”.
For more information on our data retention periods, please send us an e-mail at privacy@uviu.com.
How We Protect the Security of Your Personal Information
We take appropriate security measures (including physical, electronic, and procedural measures) to safeguard your Personal Information from unauthorized access and disclosure. For example, only authorized employees are permitted to access Personal Information, and they may do so only for permitted business functions. In addition, we use encryption in the transmission of your Personal Information between your system and ours, and we use firewalls to help prevent unauthorized persons from gaining access to your Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.
You are responsible for always maintaining the secrecy of your unique password and account information. We are not responsible for circumventions of any privacy settings or security measures contained on UVIU.
Your Rights Related to Your Personal Information
Subject to local law, you have certain rights regarding the Personal Information we collect, use, or disclose and that is related to you, including the right:
If we ask for your consent to use your Personal Information, you can withdraw your consent at any time. Note that in case of a withdrawal of your consent you may no longer be able to use several functionalities of UVIU, some of our services or the UVIU platform as case may be.
You may, at any time, send us an e-mail at privacy@uviu.com (or follow the links at the end of this Privacy Notice) to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are in the European Economic Area, you have a right to lodge a complaint with your local data protection authority.
Note that some requests to delete certain Personal Information will require the deletion of your user account as the provision of user accounts are inextricably linked to the use of certain Personal Information (e.g., your e-mail address). Also note that it is possible that we require additional information from you to verify your authorization to make the request and to honor your request.
California Rights and Choices
The California Consumer Privacy Act of 2018 (“CCPA”) provides California residents (“Consumer(s)”) certain rights with respect to their personal information, as this term is defined under the CCPA. In addition to the rights that we state under this Privacy Notice, and subject to the exceptions found under the CCPA, such Consumers have the right to:
To exercise the rights described above, please use the buttons at the bottom of this page or email us at privacy@uviu.com with the email subject line “CCPA Request.” In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled “Disclosure of Your Personal Information”.
Resident’s Rights – Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange your Personal Information with anyone for money.
Changes to Our Privacy Notice
We may modify or revise our Privacy Notice from time to time. Although we may attempt to notify you when major changes are made to this Privacy Notice, you are expected to periodically review the most up-to-date version found at this location, so you are aware of any changes, as they are binding on you. If we change anything in our Privacy Notice, the date of change will be reflected in the “Last Modified” date mentioned in the heater of this Privacy Notice.
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
We reserve the right to refuse online service through UVIU, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
No Rights of Third Parties
This Privacy Notice does not create rights enforceable by third parties or require disclosure of any Personal Information relating to users of UVIU.
Our Policy Towards Minors
UVIU prohibits minors from accessing or using its platform in any way. UVIU is forbidden to persons under the age of eighteen (18) or the applicable age of majority in the jurisdiction from which UVIU is accessed. We do not knowingly collect Personal Information from minors. If you become aware that a minor has provided us with Personal Information in any way, inadvertently, fraudulently or erroneously attempted to provide us such information with the intent to access UVIU, please contact us at support@uviu.com or at privacy@uviu.com to remove such information immediately.
Contact Information
If you have any questions about this Privacy Notice or our information-handling practices, please contact us at privacy@uviu.com.
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address dpo@uviu.com.
MANAGE YOUR PERSONAL INFORMATION DATA