Effective________

Whale TV PTE. LTD., and its subsidiaries and affiliates (“Whale TV,” “we,” or “us”) committed to providing quality services and a safe environment to users. This Privacy Policy is meant to help consumers (“you”) understand what information Whale TV collect, why it is collected and how the information is used and shared.

Where it is reasonable and practicable to do so, we will collect your personal information only from yourself. However, in some circumstances, we might be provided with information by third parties. Please rest assured as we will never sell your personal information to any third party. This Privacy Policy does not cover actions of third parties. For more information about their practices, please consult their privacy policies.

Definition means any Internet connected product which is capable of accessing the Partner Portal and has been certified by us.

“Device” means any Internet connected product which is capable of accessing the Partner Portal and has been certified by us.

“Personal Information” means any information relating to an identified or identifiable natural person, like a name, e-mail address or IP number.

“Platform” means the technical IT infrastructure that is used by us to manage and operate the Partner Portal and related network infrastructure.

“Partner Portal” means this website which is currently accessible via: https://www.whaletv.com/about-us.

“Portal” means our Smart TV Portal.

“Processing of personal information” means any operation or set of operations which is performed by us or on our behalf, upon personal information, whether or not by automatic means, such as, but not limited to collection, storage, transmission and adaptation.

“SDK” means the Software Development Kit that we offer for download at the Partner Portal.

“You” means the natural person whose personal information is collected and processed by us.

Why Whale TV Collect Information

To enable building of better services and improvement of our services, third parties and our party need to collect your personal information. Personal information collected by us is used for the following purposes:

• Support and maintenance: to provide you with quality and maintenance services, and to handle and meet your requirements.

• Improve our products and services: we use your information to make improvements in our products and services.

3. Develop new services: we use the information we collect in existing services to help us develop new ones.

4. Service communications and customer cares:

we use information we collect, e.g. your email address to send you service information, for example, we may inform you of upcoming changes or improvements in our services, or respond to your comments and questions and provide customer services;

5. Protect users, the public and Whale TV:

we use collected information to help improving safety and reliability of our services. This includes protecting, detecting and deterring fraudulent, unauthorized, infringing or illegal activities that could harm Whale TV, our users or the public.

We Want You to Understand Types of Information We Collect as You Use Our Services

We collect information to provide better services to all our users. What information we collect and how that information is used depends on how you use our services and how you manage your privacy controls. A large sum of personal information is collected by Whale TV, as described below.

1. Information you create or provide us

When you sign up for an account, you will provide us your personal information that contains your first name, surname, gender, function title, company name and specific details related to your company, including its address and website. If you sign up social media accounts, we will collect information from those social networking services, including your user name, profile photo and name. If you are not authorized to accept the terms of our developer’s agreement, which we have presented to you during submitting processes of the first application, we will also request that you provide your first name, surname, title and e-mail address of a person in your company that is authorized to accept it.

During sign-up process, we will also request you to provide a password. Your personal information will be linked to combination of username all the time (e-mail address) and password of your own account. When you sign up for an account, a verification e-mail will be sent to you to confirm that we have actually received your e-mail address. All the above information is linked to combination of your username (e-mail address) and password of your account.

2. Information We Collect as You Use Whale TV Services

2.1 Browsing and Device Information

In order to provide you with basic services, we may collect browsing and device information when you use Whale TV services. Information we collect contains IP address, browser histories and settings, device type and settings, device-ID, Wi-Fi network name and connection data, country and language configured, time and date of server accessing, error logs, crash reports.

We will log your download of SDK through Partner Portal. In our log, we will retain IP address, web browsers, operating systems, country of your Internet connections, time and dates of downloads and your first name and surname (“SDK Download Information”).

We retain all information that you provide to us by means of Partner Portal when you submit a new application to us (“Application Information”). Such information contains but is not limited to application name, category preferences and commercial descriptions of an application and is linked to combination of your username (e-mail address) and password of your Partner Portal account. Application information also includes personal details of any other developer you have linked to your application for Partner Portal. If you are a legal entity, we will not treat application information as personal information.

2.2 Third-party APPs

When you use a third-party App, the third-party may receive your information including device-ID, IP address, login details and language and country configured on your device. To better understand how this information is used and how long it takes to be stored, please check privacy policies of the third party that provides the app.

2.3 Your Activities

We collect information about your activities，such as when you access to smart TV Services provided by Whale TV and when we use to do things like recommending apps you might like. Activity information we collect may contain: your search histories, key words and results, voice information when you use voice-enabled features, the commercials you view, viewing dates, time and durations and interaction information with those ads.

In Partner Portal services, the webserver that we utilize for Partner Portal logs IP address of each computer that interacts with it. As a consequence, we will retain a log of your visits to Partner Portal. This log displays IP addresses of your Internet connections as well as when and where you visited which pages through Partner Portal

2.4 Your Location

We will collect your location information when you use our services so that we can provide you some convenient and practical services. We will determine your location either by your IP address access point.

Whether we can collect your location information depends on your authorization.

What do We do with Information We Collect?

1. Authentication

We use combination of your username (e-mail address) and password to authenticate you.

2. Improve Our Services

For example, we use the application information and IP logs of webserver on Partner Portal to improve user experience through Partner Portal and to further develop it.  

3. Application Verification

We use your username (e-mail address), password, related name, company details and information provided to us when you submit an application to manage verifying and accepting processes of your applications.

4.Share Your Information

We will not share your personal information with companies, organizations or individuals outside Whale TV except in the following cases：

With your consent

We’ll share your personal information outside Whale TV when we have your consent. We’ll ask for your explicit consent to share any sensitive personal information.

For Legal Reasons

We will share your personal information outside Whale TV if we have a good-faith belief that accesses, uses, preservations or disclosures of such information are reasonably necessary to:

• Meet any applicable law, regulation, legal process or enforceable governmental request;
• Enforce applicable terms of services, including investigations of potential violations;
• Detect, prevent or otherwise address frauds, security or technical issues;
• Protect against harms to rights, properties or safety of our users, the public or Whale TV, as required or permitted by law.

For External Processing

We provide personal information to our affiliates and other trusted businesses or persons to process it for us based on our instructions and in compliance with our Privacy Policy as well as any other appropriate confidentiality or security measure. For example, we use service providers to help us with customer supports.

How Secure is Your Personal Information?

Whale TV uses industry-standard methods to secure its electronic databases of personal information. However, you should know that no company, including Whale TV, can fully eliminate security risks associated with personal information. To help protecting yourself, please use a strong password, do not use passwords that are the same as those of other accounts or services to access your account, and protect your user names and passwords to help preventing others from accessing your accounts and services.

All Whale TV products are built with strong security features that continuously protect your information. Insights we gain from maintenance of our services help us detect and automatically block security threats from ever reaching you. what’s more, if we do detect something risky that we think you should know about, we’ll notify you and help guiding you through steps to be better protected.

We work hard to protect you and Whale TV through unauthorized accesses, alterations, disclosures or destruction of information we hold, including:

• We use encryption to keep your data private in transit;
• We review our information collections, storage and processing practices to prevent unauthorized accesses to our systems;
• We restrict accesses to personal information of Whale TV employees, service providers and vendors who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet those obligations.

How Long do We Store Personal Information?

We generally store personal information as long as it is needed to provide services to you, unless we publish elsewhere in this policy that we store it for a shorter or longer period. We may store (aggregated) data longer if it is needed for taxes or auditing issues.

Information Transfers

We maintain servers in some different countries and your information may be processed on servers located out of the country where you live. Information protection laws vary among countries, of which some provide more protections than others. You consent to transfer of information to countries out of your country of residence, which may have different data protection rules compared with those in your country. Regardless of where your information is processed, we apply the same protections described in this policy. We also comply with certain legal frameworks related to transfers of data.

You Are in Control

You have the right to request accesses to your personal information that we process. You also have rights to:

(a) Rectify incorrect personal information or erase it in certain circumstances.

(b) Restrict or object to processing of your personal information.

(c) Right to erase and “right to be forgotten”.

(d) Receive your information so that you can use it elsewhere (data portability).

You also have the right to withdraw your consent any time but we would like to point out that this does not affect the lawfulness of processing before the date on which you withdraw your consent.

Updates

We may amend this Privacy Policy any time by posting amended versions on applicable Whale TV websites, by providing such notices about it or after obtaining consent to changes as might be required by applicable laws.

Contacting Us

You can send us an e-mail to privacy@whaletv.com in your own language. You can send to this e-mail address if you have any question regarding our privacy policy, and we would like to request a copy of your personal information, or tell us in advance if you want us to change or delete your personal data.