Privacy Notice

What does Viewly.me do?

Viewly.me is your launchpad to share your latest video, article, recipe, tour, store, website, social post, and other content. Our platform helps you connect your audience to all your online destinations, making your content more discoverable, easier to manage, and capable of driving revenue. Viewly.me also enables you to connect with brands and social commerce opportunities, allowing creators to monetise their content by driving traffic to various revenue-generating channels.

This Privacy Notice applies to our websites and services which include Viewly.me and their mobile app, developer portal and related software or features (collectively referred to as our “Platform” or “Viewly.me”). The Platform allows individuals and businesses to sign-up to create a personalised, easily-customisable page, monetise their content, participate in commerce opportunities, schedule social media content and/or subscribe to, follow, purchase from, or message other Viewly.me Users. It also supports visitors who interact with the Platform, businesses that interact with the brands portal, and developers who create functionality that interacts with the Platform.

In this Privacy Notice, we collectively refer to the Platform and our related services as the “Viewly.me Services”. The pages that Viewly.me Users are able to create using the Viewly.me Services are referred to as “User Profiles.” User Profiles are accessible by the public.

We are headquartered in New York, United States. For more information about Viewly.me, please see the “About” section of our Website.

How does this Privacy Notice apply to me?

This Privacy Notice only applies to personal information we collect as a controller about:

• individuals who visit and interact with the Viewly.me Services or User Profiles;
• individuals that sign up to use our Viewly.me Services via a free or paid plan;
• individuals who follow, subscribe to, purchase from, and/or message other Viewly.me Users;
• developers that sign up to our developer portal in order to build functionality that interacts with the Viewly.me Services; and
• individuals who respond to our surveys, marketing materials or participate in trade promotions or competitions that we may run from time to time.

In this Privacy Notice, we refer to all of the above individuals collectively as “Viewly.me Users.”

This Privacy Notice applies to the processing of personal information by Viewly.me as a controller. When we talk about Viewly.me acting as a “controller”, we mean that Viewly.me determines the purpose and the means of the processing (i.e. we make decisions about why and how we handle your personal information). Because of the nature of our services, we may also act as a “processor” on behalf of a Viewly.me User. In these instances, we facilitate the processing of personal information on behalf of the Viewly.me User and based on their instructions. For example, if you share your information with a Viewly.me User or make a payment to them, we facilitate this processing (“Processor Services”). This Privacy Notice does not address our Processor Services. If you subscribe to or otherwise share your information with a Viewly.me User, and want to know how they handle your personal information, please get in touch with that Viewly.me User directly and/or refer to any privacy notice they have posted on their User Profile.

If you provide us with information about another person (if, for example, you are a representative of an individual), you must provide them with a copy of this Privacy Notice and let that other person know that we use their personal information in the ways set out in this Privacy Notice.

Third-party processing and responsibilities

Viewly.me enables connections between Viewly.me Users and third parties, such as brands, advertisers, social platforms, and affiliate partners. Once you interact with a third party—such as by clicking a link, subscribing to a brand’s updates, or making a purchase through a third-party link—Viewly.me does not control how your personal information is processed by that third party.

We strongly recommend reviewing the privacy policies of any third parties you interact with via Viewly.me. If you have concerns about how a third party handles your personal information, please contact that third party directly.

Information we collect

The personal information that we may collect about you broadly falls into the following categories:

Information you provide voluntarily

When you use and/or engage with the Viewly.me Services, we may ask you to provide personal information voluntarily.

Account and Profile Information: When you create a Viewly.me account, we will ask you to provide some information which may include your email address, name, username, profile picture, biography, social media handles, and other profile information.

Payment and Transaction Information: If you use a paid plan or engage with one of our commerce products, we will ask for additional information, such as your full name, billing email address, billing address and payment method. We will also collect information about your purchase history and transaction records. We collect this information in order to facilitate billing or to make commission payments to you.

Communication Data: If you choose to subscribe to or message an Viewly.me User, we may collect information such as an email address to facilitate these services and your communication preferences. You may also provide us with your personal information when you submit queries or make a report to us (such as an Intellectual Property Report or Counter Notice). For example, we may ask you to provide your name and email address so that we can respond to your queries. If you are making an Intellectual Property Report or Counter Notice, we ask you to provide your name, address, email address, phone number and details regarding the intellectual property rights concerned.

Shared Interaction Data: In some situations, a Viewly.me User might request that you provide information, which may include your email address, mobile number, date of birth or age, or other personal information, in order to share updates, join their community, or to access elements of their User Profile (such as locked content). Similarly, if you choose to connect with a brand on Viewly.me, you may provide additional personal information voluntarily when communicating with the brand in-platform.

Survey and Promotions Data: You may also provide personal information voluntarily if you respond to our surveys, marketing materials, or through your participation in trade promotions and competitions we may run from time to time. This may include, for example, your name, contact details, demographic information, preferences, or responses to specific questions, depending on the nature of the survey or promotion.

Information that we collect automatically

When you use the Viewly.me Services, we collect certain information automatically from your device. In some countries, including countries in the European Economic Area and the UK, this information may be considered personal information under applicable data protection laws.

Usage and Analytics Data: We collect information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), time zone, usage data, diagnostic data and other technical information. We may also collect information about how you arrive at Viewly.me Services, including the referring website or service, and how you interact with the Viewly.me Services and User Profiles, including the pages accessed and links clicked. Collecting this information enables us to better understand you, where you come from, and what content is of interest to you, and enables us to share useful analytics with Viewly.me Users and business partners. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “How do we use cookies and similar tracking technology” below.

Content Moderation Data: We may undertake automatic scanning of User Profiles and links to support compliance with our Terms of Service and/or Community Standards, which may include determining whether mandatory or default sensitive content warnings should be applied and presented to people who wish to access the relevant User Profile or linked content. The results of this scanning may also help determine if any content should be removed or any User Profiles should be suspended in line with our Community Standards and/or Terms of Service, while also informing suitability for certain features, including monetisation opportunities such as affiliate marketing and sponsorships. When a Viewly.me User changes their User Profile, we may also notify relevant subscribers to that User Profile that updates have been made.

Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources. Those sources include service providers that assist with marketing campaigns or competitions and our partners who help us provide our Viewly.me Services.

Affiliate and Commerce Data: Social media networks may provide your profile picture and follower information to help us to connect Viewly.me Users (including you) with brands, retailers and affiliate networks (“Affiliate Partners”) as part of the Viewly.me Services. Similarly, Affiliate Partners may provide information on completed transactions that originate from a link on a User Profile to track and process commission payments. We may also receive information from our payment processors to support commerce products, enabling us to calculate commission payments and provide services to Viewly.me Users such as transaction dashboards. In all cases, we ensure that these third parties have your consent or are otherwise legally allowed or required to share your personal information with us.

Information that we collect in connection with recruitment activities

If you apply for a role at Viewly.me, we will collect, use and access your personal information for recruitment purposes. This may include your name, contact information, resume, references, and any other details you choose to submit. If your application is unsuccessful, we may retain your information on file for a maximum of two years for consideration in future opportunities. You can request to opt out of this retention at any time. After two years, your information will be anonymised for statistical purposes.

How we use the information we collect

We will use the information we collect for the purposes described in this Privacy Notice or for other purposes that we explain to you at the time we collect your personal information.

In some countries, including countries in the European Economic Area and the UK, we are required to have a legal basis to process your personal information. These legal bases include, first, the performance of a contract—this applies when we need to process your information to provide you with the Viewly.me Services under our Terms of Service, or to take steps before entering into a contract with you. We may also rely on our legitimate interests, where processing your information is necessary for our business and those interests are not overridden by your rights. In some cases, we process your information based on your consent—this means we will ask for your permission before using your information for certain purposes. Finally, we may need to process your information to comply with legal obligations, such as responding to lawful requests.

The table below provides a summary of the purposes for which we process your personal information, the legal basis we rely on in each case, and the categories of information involved. This is intended to give you a clear overview of how and why we process your information.

Children’s data

Our services are not intended for use by children under the age of 18 (the “Age Limit”). If you are under the Age Limit, please do not use the Viewly.me Services and do not provide us with your personal information. If you are a parent or guardian and you are aware that an individual (of whom you are a parent or guardian) under the Age Limit has provided us with personal information, please contact us. We will, upon notice or discovery, take all reasonable efforts to delete any personal information that may have been collected or stored by us about that individual.

How and when we share the information we collect

We may disclose your personal information to the following categories of recipients:

• to our group companies and third party services providers (for example, to support the delivery of the Viewly.me Services, provide functionality, facilitate payments, fulfill tax obligations, or enhance the security of the Viewly.me Services);
• with our Affiliate Partners (for example, to facilitate social commerce opportunities and support other revenue-generating opportunities) and brand partners (for example, to connect Viewly.me Users with brands for partnership opportunities). This may include location data, conversion metrics, engagement rates, messaging response rates, and other activity data and analytics;
• with other Viewly.me Users if you choose to subscribe to or sign up to be part of their community, or download or purchase content from them. If you engage with a Viewly.me User in these ways, they receive information about you to help them better understand and serve their community, including information needed to add you to their community outside of the Platform where applicable, and information needed to be able to provide the paid content;
• with third parties who facilitate log-in to the Viewly.me Services, such as Apple, Google and any other social media platform that we introduce for social log-in;
• to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
• to an actual or potential buyer (and their agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer they must use your personal information only for the purposes disclosed in this Privacy Notice; and
• to any other person with your consent to the disclosure or notified to you when we collect your personal information.

Depending on how you use the Viewly.me Services and your geographic location, we may disclose your personal information to third parties whose products are advertised on our Platform or who wish to engage in advertising on our Platform.

Disclosure of personal information to other countries

Your personal information may be transferred to and processed in countries other than the country in which you are a resident. These countries may have data protection laws that differ from, and in some cases may be less protective than, the laws of your country.

Specifically, Viewly.me may transfer personal information to the United States (where our headquarters are based) and other countries where we conduct business. We may also subcontract certain activities and share your personal information with third parties located in other countries. The countries where these organisations are located will vary, but we generally disclose personal information to organisations located in the United States. These transfers are necessary to provide the Viewly.me Services and carry out the activities described in this Privacy Notice.

We have taken appropriate safeguards to ensure that your personal information remains protected in accordance with this Privacy Notice and applicable data protection laws. These safeguards include entering into data transfer agreements between our group companies. Similar safeguards have been implemented with our third-party service providers and partners, and further details can be provided upon request.

How do we use cookies and similar tracking technology?

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice.

How long do we retain your personal information?

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice and in accordance with applicable legal and regulatory requirements in respect of permitted or required retention periods and limitation periods relevant to legal action.

How do we secure your personal information?

We have implemented technical, administrative, and physical safeguards to ensure the security of your personal information. These controls include industry-standard encryption, firewalls, intrusion detection, logging, monitoring and regular audits.

In the unlikely event of a data breach, we have a robust incident response plan to mitigate harm and notify affected individuals where we are legally required to do so.

What are your rights in relation to personal information?

Your rights may depend on where you live and the laws that apply to you. You can use our Data Request Form to:

• Access, correct, update or request deletion of your personal information.
• Object to or restrict how we process your personal information.
• Request portability of your personal information.
• Opt out of receiving marketing communications. You can also exercise this right by clicking on the unsubscribe or opt-out link in the marketing materials we send you.

If you have given consent to the processing of your personal information, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on other lawful grounds. Depending on the country which you live in and the laws that apply to you, you may also have additional data protection rights.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. In some instances, we may need to verify your identity before granting you access to your personal information or complying with your request.

Your U.S. State Privacy Rights and Additional Disclosures

Depending on the U.S. state in which you reside, you may have certain privacy rights regarding your personal information. If you are a California resident, please see the “Supplemental Information for California Residents” section below. For other state residents, your privacy rights may include (if applicable):

• The right to confirm whether or not we are processing your personal information and to access such personal information and the categories of personal information we are processing or have processed about you;
• The right to obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
• The right, at our option, to obtain a list of the categories or specific third parties to which we have disclosed your personal information;
• The right to delete your personal information, subject to certain exceptions;
• The right to correct inaccurate personal information that we maintain about you, subject to certain exceptions;
• The right, if applicable, to opt out of the processing of your personal information for purposes of (1) targeted advertising; (2) the “sale” of your personal information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
• If we are required by applicable law to obtain your consent to process sensitive personal information, the right to withdraw your consent; and
• The right not to receive discriminatory treatment by us for the exercise of your privacy rights.

To exercise your rights, please submit a request through our Data Request Form. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request.

Supplemental information for Californian residents

The California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (“CCPA”), requires that we provide California residents with a privacy policy that contains a comprehensive description of our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of personal information and of the rights of California residents regarding their personal information. This section of the Privacy Policy is intended solely for, and is applicable only as to, California residents. If you are not a California resident, this section does not apply to you and you should not rely on it.

The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Supplemental Information for California Residents” section we will refer to this information as “Personal Information.”

Complaints

We take your privacy concerns seriously. If you have a complaint regarding our handling of your personal information or concerning our privacy practices, you may file a complaint with us using the contact details provided under the “How you can contact us” heading below. We will confirm receipt of your complaint and, if we believe necessary, we will open an investigation.

We may need to contact you to request further details of your complaint. If an investigation has been opened following a complaint made by you, then we will contact you with the result as soon as possible. In the unlikely circumstances we are unable to resolve your complaint to your satisfaction, you may contact the local privacy and data protection authorities in your jurisdiction.

Changes to This Privacy Notice

We may update our Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How You Can Contact Us

If you have any questions about this Privacy Notice or our privacy practices, or if you would like to make a request about any personal information we hold about you, please contact us:

• By email using: privacy@viewly.me
• By visiting our help page
• By post at Viewly.me, New York, United States