Privacy Policy
Introduction
Real Vision Group SEZC and its subsidiaries and affiliates (collectively, “Real Vision,” “we,” “us,” and “our”), want you to be familiar with how we collect, use and disclose information from and about you because we understand you are concerned about your privacy, and we want to maintain your trust.
This Privacy Policy applies to information we collect from our website at www.realvision.com (“Site”) and our applications (“Apps”, together with Site, referred to below as the “Real Vision Services” or the “Services”) that link to this Privacy Policy. This privacy policy does not apply to any other websites, apps or services provided by us, our affiliates or clients, unless it appears on such website, app or service.
Your use of our Services is also governed by the Terms of Use published at https://www.realvision.com/terms/ (“Terms of Use”). By using the Real Vision Services you agree both to our Terms of Use and the terms and conditions of this Privacy Policy.
Information We Collect
Your provision of your personal information to us is completely voluntary. “Personal information” is information that can specifically identify you. Categories of personal information we may collect include:
- Identity Data,which includes name or other similar identifiers.
- Contact Data,which includes address, email address and telephone numbers.
Additionally, we may also collect certain others types of information that, along with Identity Data and Contact Data, may be considered and specifically named “personal data” in certain jurisdictions, including the European Union (“EU”), such as:
- Financial Data,which includes credit card, debit card or other payment card details. To see more details about our collection of your Financial Data through third parties, please see the section titled “Collection of Personal Financial Information by a Payment Service” below.
- Transaction Data,which includes details about payments to and from you.
- Technical Data,which includes internet protocol (IP) address, location data, your login data, and device and browser information.
- Profile Data,which includes your username and password, your interests and preferences.
- Usage Data,which includes information about how you use our Site and Partner Sites and advertising we serve on those sites.
- Marketing and Communications Data,which includes your preferences in receiving marketing from us.
IF YOU ARE SITUATED IN THE EU, PLEASE SEE THE SECTION “ADDITIONAL EU DISCLOSURES” THAT PERTAIN TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.
We use different methods to collect information from and about you:
Directly from you: We collect information about you when you provide them to us. For example, we collect your information when you register for or subscribe to certain products or services; create a membership profile; participate in a sweepstakes, contest or game; take a survey; visit our Real Vision Services; use any interactive features; participate in a community forum; or contact our customer service representatives through the messaging functionality made available to you on the Site and through the Services.
From Third Parties: We may receive information about you from third parties, such as social media services, commercially available sources, Real Vision Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Information we receive from third parties may include, for example, your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. For example, if you access Real Vision Services through a social media service or connect the Real Vision Services to a social media service, the information we collect may also include your user name associated with that social media service, any information or content the social media service has the right to share with us, such as your profile picture, email address or friends list, and any information you have made public in connection with that social media service. When you access the Real Vision Services through social media services or when you connect the Real Vision Services to social media services, you are authorizing Real Vision to collect, store, and use such information and content in accordance with this Privacy Policy. We may also receive information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.
From automated technologies or interactions: As you interact with our Site, we may automatically collect Technical Data and Usage Data about your. Some of the ways in which we or our Site may collect are further described below:
- Cookies and other tracking technologies: When you access and interact with our Real Vision Services, we and our service providers may automatically collect certain information about those visits. For example, in order to permit your connection to the Real Vision Services, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. Real Vision and our service providers also may use cookies and other tracking technologies (such as browser cookies, pixels, beacons, and Adobe Flash technology) when you visit or use the Real Vision Services. Third parties that support the Real Vision Services by serving advertisements or providing services, such as providing users with the ability to comment on content, allowing users to share content, customizing content based on usage, or tracking aggregate site usage statistics, may also use these technologies to collect information on the Real Vision Services and on other websites.Please see our Cookie Policy for further details.
- Push Notifications: If you access the Real Vision Services from a mobile device or through an App, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information for that device. We use this information to help us maintain and enhance the efficiency and usefulness of the Services and may use it and other non-personal information for the purposes described in this Privacy Policy. Additionally, we may also receive location data from other third parties. We may use our Apps to obtain the user’s location if the user of the App permits the App to request and collect this information from the applicable mobile device. We also may enable our Apps to offer automatic (or “push”) notifications. We will provide push notifications only to those users who permit such notifications. If you would like to opt-out of location based advertising and push notifications, please see the “Choices and Access” section below.
- Flash technologies: Our Site may also use Flash technologies. You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website, http://www.adobe.com/devnet/security.edu.html. Please note that by blocking any or all cookies you may not have access to certain features or personalization available through our Real Vision Services.
- Interest-Based Advertising: We may engage third-party vendors to use your information in connection with their own information to deliver targeted advertising to you when you visit our Site or other websites. Cookies, described above, may be used in this process. For example, if you are searching for information on a particular product, our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising is called “behavioral advertising”. We believe that such advertising is helpful because you will see ads that are relevant to your interests. However, if you would like to opt-out of these interest-based advertisements, please see the “Choice and Access” section below.
Collection of Personal Financial Information by a Payment Service
In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). Depending on the product or services involved, your financial information may be collected in one of two ways:
- You may be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service; or
- You may be making purchases directly through our Services without being routed to a Payment Service webpage, where you may provide payment information (such as payment card number and expiration date). This information is used by our Payment Service for one-time and recurring billing purposes according to the type of product ordered and the terms pertaining thereto, and to fulfill your orders. Payment card information is sent in encrypted format and is used only to send to our Payment Service, for the purposes of collecting payment for services rendered or to be rendered. We never make this information visible to anyone other than our Payment Service and never communicate it over a non-encrypted connection. The full payment card number is never seen by anyone inside our company, once entered and submitted, except by our Payment Service for the purposes of authorizing, clearing and reversing charges to your payment card. If we (or our Payment Service) have trouble processing an order, we (or our Payment Service) may use your Personal Information to contact you.
How we Use Your Information
Subject to the section titled “Additional EU Disclosures”, we use information held about you to perform our services and for other purposes outlined below:
- To provide our products, services and features to you including: to process and fulfill your subscription, to send you information about your relationship or transactions with us, to measure and improve those services and features, to allow you to comment on content and participate in online games, contests, promotions or rewards programs, use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chats, and to respond to inquiries.
- To improve the quality of our products and services
- To personalize your experience by presenting content, products and offers tailored to you
- Combine your information with other information relating to your use of other Real Vision products, services and websites
- Supplement your information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from Real Vision Affiliates or business partners
- To deliver relevant online advertising
- To send you marketing materials
- To allow social sharing functionality
- To contact you to respond to your direct inquiries
- To perform specific services you have requested
- Where we need to comply with a legal or regulatory obligation
- To protect the rights of Real Vision and others
How We Share Your Information
Real Vision and its subsidiaries may share your information with one another, as well as with Real Vision Affiliates for the purposes described in this Privacy Policy, including for each company’s marketing purposes. Users who visit Real Vision Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. Real Vision is the party responsible for the management of the jointly-used Personal Information.
Subject to the section titled “Additional EU Disclosures”, we may share the information we collect about you with certain non-affiliated third parties in the following ways:
- To manage corporate, third-party, and school subscriptions:If your subscription is provided in whole or in part by your employer or other third party, we may notify the provider when you access or use your subscription. If you have a subscription associated with a professor or school, we may notify your professor or school to confirm your subscription, access or use. When providing these notices, we may reveal limited amounts of your Personal Information such as your name or email address.
- To allow third-party service providers to assist us in providing and managing our services:We may make your information available to certain third-party service providers, such as contractors, agents or sponsors, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; and serving, customizing or delivering marketing or ads. These outside service providers are required to protect your information entrusted to them and not use it for any other purpose than the specific service they are providing to us.
- To provide co-branded services and features:We may offer co-branded services or features, such as conferences, contests, sweepstakes or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted on the Real Vision Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy policy.
- To allow social sharing functionality:If you log in with or connect a social media service account with the Real Vision Services, we may share your user name, picture, and likes, as well as your activities and comments with other Real Vision Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Real Vision Services account and your social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends, and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy policy. If you do not want your Personal Information shared in this way, please do not connect your social media service account with your Real Vision Services account, and do not participate in social sharing on the Real Vision Services.
- To protect the rights of Real Vision and others:We may disclose your information, including situations where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of Real Vision, our Real Vision Affiliates or their employees, agents and contractors (including enforcement of our agreements and our Terms of Use); (ii) protect the safety, privacy, and security of users of our products and services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.
- To complete a merger, sale of assets, or bankruptcy:If Real Vision sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger, bankruptcy, or transfer of all or a material part of its business, Real Vision may transfer your information to the party or parties involved in the transaction as part of that transaction.
Certain features on the Real Vision Services give you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging and commenting on articles. When you use these features, you should be aware that any information you submit, including your name, user name, location, email address, profile information, picture, likes, status, and comments, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the Real Vision Services. We are not responsible for any information you choose to submit and make public through these interactive features.
Security
Real Vision uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Information in its possession against loss, theft and unauthorized use, disclosure or modification. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting our customer service representatives through the messaging functionality made available to you on the Site and through the Services.
Retention
We will only retain your 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 your information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of your information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymize information about you (so that it can no longer be associated with you) for research or statistical purposes in which case we may use and retain this information indefinitely without further notice to you.
Additional EU Disclosures
Our role as data controller and data processor
Real Vision Group SEZC is the data controller of your information submitted through our Site. If you are situated in the EU and have any complaints regarding our privacy practices as data controller, you have the right to make a complaint at any time to your local Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach your Supervisory Authority so please contact us in the first instance. Please see our contact details below in the section titled “Contact Us”. If you are situated in the EU and have a complaint, please contact our privacy manager can be contacted here: milton@realvision.com.
Provision of personal data and failure to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we will not be able to provide services to you.
Legal basis for our processing of your personal data
Below are the types of lawful basis that we will rely on to process your personal data:
- Legitimate Interestmeans the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at milton@realvision.com.
- Performance of Contractmeans processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligationmeans processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at milton@realvision.com. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Withdrawing your consent
If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. You have the right to withdraw your consent at any time by contacting us at milton@realvision.com.
Use of your personal data for marketing purposes
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:
- Promotional offers from us: We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or used our services and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We currently do not share your personal data with any third parties outside our company for marketing purposes.
To see how you can opt out of marketing communications, please see the “Choice and Access” section.
Rights of EU Data Subjects
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
To exercise your rights, please contact us at milton@realvision.com.
Choices and Access
Your Choices Regarding Our Use and Disclosure of Your Personal Information
We give you certain choices regarding our use and disclosure of your Personal Information for marketing purposes.
You may opt-out from receiving electronic communications from us (including surveys or notifications) by changing your account settings through the appropriate link on the Site account services page or following the unsubscribe instructions at the bottom of each email or contacting us at milton@realvision.com.
Please note that there are certain service notifications that you may not opt-out of, such as renewal notices and notifications of changes to Real Vision products and services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
How to Access, Correct or Update Your Personal Information
You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting our customer service representatives through the messaging functionality made available to you on the Site and through the Services. Most subscribers can also update their information online by signing on to their accounts and visiting the appropriate account management sections of our Sites.
You may also contact Real Vision’s customer service representatives through the messaging functionality made available to you on the Site and through the Services or email us at milton@realvision.com. For your protection, we may only implement requests with respect to the information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
Opting out of interest based advertising
The online advertising industry provides a service through which you may opt-out of receiving targeted ads from certain data partners and other advertising partners that participate in self-regulatory programs. To be clear, cookie-based opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device.
Do Not Track Signals
With respect to “do not track” (a/k/a DNT) signals or similar mechanisms transmitted by web browsers, the Services do not respond to or honor such signals or mechanisms. This means that third parties, such as ad networks, web analytics companies, and social networking platforms may collect information about your online activities over time and across our Services and other third-party online properties or services. These companies may use information about your visits to our Properties and other sites, and general geographic information derived from your IP address, in order to provide advertisements about goods and services of interest to you. For more information about third-party advertisers and how to prevent them from using your information, please visit http://www.networkadvertising.org/choices/.
Opting out of cookies
If you want to stop or restrict the placement of cookies or flush any cookies that may already be on your computer or device, please refer to and adjust your web browser preferences. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our Site or some of its functionality may be affected. For more information about cookies, please visit our Cookie Policy.
Opting out of location tracking
In some cases, such as when using an App, you may also adjust the settings on your mobile device to allow or restrict the sharing of location information. For example, the “location” permissions on your mobile device may allow you to elect whether to never share location information with us, to share location information only while you are using an app, or always share location information even if you are not using an app. If you elect to not share your location information, you may be unable to access some features of our Services that are designed for mobile devices. Also, in the event that you prevent the sharing of location information, we may still estimate your general location based on the IP address you use to access our Services.
Mobile Application-Based Opt-Outs
Cookie-based opt-outs are not effective on mobile applications. You may opt out of certain advertisements on mobile applications or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, click on the following links:
Your California Privacy Rights
California law permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes, including: (a) a list of the categories of Personal Information, such as name, email address and mailing address and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us at milton@realvision.com. If you do not want your Personal Information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at milton@realvision.com.
Linked Services and Social Networking Services
The Real Vision Services may also be linked to sites operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties. Some of these third party sites may be co-branded with a Real Vision logo, even though they are not operated or maintained by us. Real Vision is not responsible for the privacy practices of any such third parties, and once you leave the Real Vision Services or click an advertisement, or sign up for a special offer, you should check the applicable privacy policy of the other service.
The Services may also integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
Children’s Information
The Real Vision Services are a network of general audience sites, and are not targeted to, and do not knowingly collect Personal Information from, minors under 18 years of age. We request that these individuals do not provide Personal Information through the Real Vision Services or otherwise use or access our Services.
The Services may also integrate with social networking services. You understand that we do not control such services and are not liable for the manner in which they operate. While we may provide you with the ability to use such services in connection with our Site, we are doing so merely as an accommodation and, like you, are relying upon those third party services to operate properly and fairly.
You should be aware that information which you voluntarily include and transmit online in a publicly accessible blog, social network or otherwise online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.
International Visitors
Our Site and App is hosted in the United States. If you are visiting from the regions with laws governing data collection and use that may differ from those in the United States, please note that you may be transferring your information to the United States and in other countries around the world. You freely and specifically give us your consent to export and use your information within the United States and in other countries as specified in this Privacy Policy. You understand that data stored in the United States and other countries may be subject to lawful requests by the courts or law enforcement authorities in such countries. If you are situated in the EU, whenever we transfer your personal data to processors outside of the EU, we ensure appropriate and suitable safeguards are used in such transfer. We may use specific contracts approved by the European Commission which give personal data the same protection it has in the EU For further details.
Updates to Privacy Policy
Real Vision may modify this Privacy Policy. Please look at the effective date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Real Vision Services. Your use of the Real Vision Services or your provision of Personal Information to us following these changes means that you accept the revised Privacy Policy.
Contact Us
If you have questions about this Privacy Policy, please contact us at milton@realvision.com through the messaging functionality made available to you on the Site and through the Services. We ask that you not disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) when contacting us, as we do not require such information from you.