Playsee Privacy Notice
At Playsee, we are committed to protecting your privacy, and this Privacy Notice ("Privacy Notice") was written to set out our privacy practices and explain what personal data relating to you we collect, how we use it, and what choices you have when you visit and use our Playsee mobile applications, website, content and other products and services ("Services").
Playsee is a public open network platform that allows you to create and post content including videos, comments and other material that you generate (“User Content”). Any information or User Content that you choose to share or disclose by using the Service will be available and potentially searchable by anyone in the world. We give you non-public ways to communicate on Playsee through Messages. You can also use Playsee under a pseudonym if you prefer to not use your name.
I. Scope and Application
The Privacy Notice applies to persons who access and use our Services.
II. Data Controller
The responsible data controller for any personal data collected and processed in connection with the access and use of our Services is Framy Inc. ("Framy", "we" or "us").
III. What Personal Data Do We Collect?
Personal Data You Provide to Us
We require certain information in order to provide our Services to you. When you choose to share the information below with us, we process it to operate our Services:
We create an account for you with a default user ID (for example, “user.abc123”) when you first open the Playsee app in order for you to upload, interact, and share content on Playsee. You then have the option to personalize your account by changing your default user ID to one of your likings, and by providing us with some personal data such a nickname, a password, and an email address. Your user ID and nickname are always public, but you can use either your real name of a pseudonym.
You may choose to provide additional account information, namely, your birthday, gender, and a short biography. Birthday and gender are private information and will not be shared with other users. Short biography will be public for others to see.
To help you connect with your existing friends, you have the option to choose to enter your phone number by going to the Find Friends section and by entering the phone number and clicking “OK”, we will sync your phone book or contact list to help you and your friends find each other. We do so by cross-referencing the phone numbers in your address book with other users who have also registered their phone numbers. Mutual consent is required from both users before we can cross-reference your other friend who is also using Playsee. If your friend signs up for Playsee at a later date, he/she shall be able to find your Playsee account upon providing phone number and giving consent.
We also collect your contact information, email or phone number, for multiple reasons, upon you giving us the consent. However, without your further consent to make such information public, they will remain private. By purchasing our Contact Options or upgrading your account to a business account, your contact information will be shared upon further notice and consent.
If you email us, we will keep the content of your message, your email address, and your contact information to respond to your request.
We process User Content, namely, any videos, information, text, graphics, photos, music, sounds, voice, likes, comments, shares, collections, saves, hashtags, and location data you create.
We provide message feature to have non-public conversations on Playsee. When you communicate with others by sending or receiving Messages, we will store and process your communications and information related to them. This includes link scanning for malicious content, detection of spam and prohibited contents, and review of reported issues. We also process information about whom you have communicated with and when (but not the content of those communications) to better understand the usage of our services, to protect the safety and integrity of our platform, and to show more relevant suggested content. We only share the content of your Messages with the people you have sent them to. Remember, when you use the messages feature to communicate with other users, the recipients have their own copy of your communications on Playsee - even if you delete your copy of those messages from your account.
When you purchase advertising services or other offerings provided as part of our Services, we receive limited information related to a purchase you made, namely, a user identification number, from Stripe, a third-party service provider used to process payments.
Stripe acts as a separate controller, and hence any information you provide (namely, your legal name, credit or debit card number, card expiration date, CVV code, and billing address) to Stripe is not governed by this Privacy Notice. Please also refer to Stripe’s Privacy Notice for your knowledge about the processing of your payment information by Stripe.
Personal Data in Using the Services
We process the following personal data when you use our Services:
We process information on how you use the Services—the types of content that you view or engage (like, comment, collect, save, and share) with, the features you use, the actions you take, the people or accounts you interact with and the time, as well as the frequency and duration of your activities.
When you interact with the Services, we process log file information, namely, server logs, access dates and times, operating system, browser type, your IP address, language, your clicks, your views, your engagements, search terms, app features or pages viewed, time spent on each page viewed or on each feature, and other system activity.
We process information about your mobile device when you use it to access our Services:
Information about your hardware and software, namely, your device model, operating system version, device memory, advertising identifiers, unique application identifiers, apps installed, unique device identifiers, browser type, language, battery level, and time zone.
Information from device sensors, namely, accelerometers, compasses, microphones, and whether you have headphones connected.
Information about your wireless and mobile network connections, namely, mobile phone number, service provider, and signal strength.
Unique identifiers, device IDs and other identifiers from the Facebook or Google accounts that you choose to integrate with Playsee when you sign up.
If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
Camera and Phone’s Photos/Albums
Many of our services require us to collect videos and other information from your device’s camera and photos/albums (depending on how your device called the folder for storing your photos and videos). You won’t be able to upload content from your camera roll unless we can access your camera or photos/albums. We process data such as the album names you have, the videos/photos you store in each album, the time and location the content was taken, and the number of content in each album.
Data from device settings.
Information that you allow us to receive through device settings that you turn on, namely, access to your GPS location, camera, photos, and microphone from your phone.
We require information about your location, which we receive from signals of your IP address, Wi-Fi points you are accessing the Service through, mobile/cell tower triangulation, or device settings.
You may choose not to provide certain types of personal data to us unless the provision of personal data is required for the performance of Playsee and to provide you with the Services. If you choose to not provide these types of personal data, our ability to provide you with, and your ability to make use of, the Services may be affected.
Playsee uses a third-party hosting partner to run Playsee's infrastructure. Because these hosting partners and their facilities are located worldwide, we may necessarily be required to transfer the information we collect from you and store it in other countries. Please see the section "Cross Border Data Transfers" for more information on international data transfers and the safeguards we use in this regard.
We take appropriate technical and organizational security measures to protect the personal data we have collected. However, please note that no security measures are perfect or impassable.
IV. Why Do We Collect, and On Which Legal Basis Do We Process Personal Data?
The purpose behind processing your personal data is to provide and improve the Services that our service offers. By collecting the information, we can test, diagnose and maintain our Services, monitor ads and metrics, personalize your user experience, connect you to your friends or other users, research and develop new products and features, fix technology problems, send you updates or communicate with you, and protect our community and User Content.
More specifically, the following shows which personal data we process for which purpose and under which legal basis:
Purposes of the Processing:
|Purposes of the Processing||Categories of Personal Data and Information on Cookies Used (if applicable)||Legal Basis for the Processing|
|Personalization of your account. Creation of an identity with our Services. Authentication mean of your account and use of the Services. Protection of your data within the account.||Account information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR), and based on our legitimate interests* (Art. 6 (1) (f) GDPR) and/or based on your consent.|
|Encouragement of social networking and connecting with existing friends as well as future friends. Promotion of yourself and/or business. Communication with us.||Contact information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR), based on our legitimate interests* (Art. 6 (1) (f) GDPR), and/or depending on the individual activity, based on your consent (Art. 6 (1) (a) GDPR).|
|Content sharing. Accuracy and legitimacy (in accordance with our Terms of Services) in location check-in. Provision of nearby location suggestions.||User content Location information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR), based on our legitimate interests* (Art. 6 (1) (f) GDPR), and/or depending on the individual activity, based on your consent (Art. 6 (1) (a) GDPR).|
|Enhancement of private communication with other users.||Messages||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR), and/or based on our legitimate interests* (Art. 6 (1) (f) GDPR).|
|Payment processing of paid features.||Payment information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR) and based on your consent.|
|User experience. Personalization of content to provide relevant content and engaging experience.||Usage information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR) and/ or based on our legitimate interests* (Art. 6 (1) (f) GDPR).|
|Administration. Operation. Maintenance. Security. Improvement. Technical and customer support to you.||Account information Log data Device information Identifiers Videos and other information from your device’s camera Data from device settings Location information Usage information Payment information User Content Contact Information||The processing is required for the performance of a contract (Art. 6 (1) (b) GDPR), and based on our legitimate interests* (Art. 6 (1) (f) GDPR) and based on your consent.|
*For data processing activities based on legitimate interests (Art. 6 (1) (f) GDPR): Further information on the balancing test performed are available upon request to email@example.com.
Please note that we process your personal data for other purposes only if we are obligated to do so on the basis of legal requirements (e.g., transfer to courts or criminal prosecution authorities), if you have consented to the respective processing or if the processing is otherwise lawful under applicable law. If processing for another purpose takes place, we will provide you with additional information.
V. Who Do We Share Personal Data With, and When?
Who - Data Recipients
Playsee shares your personal data for the respective purposes to the recipients and categories of recipients listed below:
Other Users and the Public.
The public at large and your fellow users will have access to the information or User Content you have published or uploaded onto our Services. Your user ID, nickname, and short biography are shared in the community. If you share User Content, namely, comments, videos, likes, collections, locations, publicly, it will be available to everyone. You should also keep in mind that even if you intend to share User Content only with select users (and accordingly applied the appropriate privacy settings), those users, and other persons (as the case may be), may use other methods and devices to capture and share your User Content or information without your permission.
You are responsible for your videos and other information you provide through our services and you should think carefully about what you make public, especially if it is sensitive information. If you update your public information on Playsee, such as by deleting a video, we will reflect your updated content on Playsee for iOS and Playsee for Android.
Third Party Applications.
Your User Content and personal data may be shared with certain social networking or third-party applications or services, if you choose to allow them to connect to our Services. We share your information with the following third parties:
- Social Network.
If you choose to sign up with Playsee by using a social network, Facebook or Google, or connect your existing Playsee account to other social networks, such social networks will ask for your consent to grant access of your unique user ID, name, email and profile picture to Playsee. This is done to allow for a more convenient sign up and log in. During the process, you will be prompted to provide consent via a popup notice informing you that by selecting “Continue”, you will allow the platform to share information about you.
Information can be shared with social networks when users share profiles, videos, and locations to other third-party platforms, namely, Facebook, Messenger, Message, Twitter, WhatsApp, Line and Email, and more if users copy link. This information can be your user ID, number of videos, number of followers, the location, the video, and a URL to the shared content. Information collected by these third-party services is subject to their own terms and policies.
- Third Party Service Providers.
We use third party service providers to provide services and products on our behalf and will share your personal data with them as necessary for the provision of the Services. Our service providers are contractually obligated to process such data on behalf of Playsee under appropriate instructions as necessary for the respective processing purposes and to appropriately protect your personal data. Our service providers may not otherwise process or share your personal data, except as permitted by law. For example, we share your Playsee ID, email, and name with payment services providers to process payments and provide technical and customer support; prevent, detect, and investigate fraud or other prohibited activities and other purposes associated with the credit and debit cards. Your Playsee ID and email is also shared with Amazon Web Services to enable push notifications and email services to reset your password. User content is shared and stored on Google Cloud Platform. We also share your personal data with analytics and search engine providers, namely, Google Analytics, Firebase, Facebook Analytics, App Store Connect, and Google Play Console, that assist us in the optimization and improvement of the Services. We may collect information about how you use our services over time and combine it with similar information from other services and companies. This information may be used to, analyze and track usage and data, determine the popularity of certain content, content moderation, crash analytics, and better understand your activity.
We transfer your personal data to our affiliated companies UTW Technology Co., Ltd. and Framy Inc. Hong Kong Limited, providing infrastructure, systems and technology services to us enabling us to provide you with a relevant, innovative, consistent and safe experience across all the products you use. These affiliated companies are contractually obligated to process such data on behalf of Playsee under appropriate instructions as necessary for the respective processing purposes and to appropriately protect your personal data and may not otherwise process or share your personal data, except as permitted by law.
- Governmental authorities, courts, external advisors, and similar third parties that are public bodies.
We will share personal data as required or permitted by applicable law with governmental authorities, courts, external advisors, and similar third parties that are public bodies, in order to: (i) ensure compliance with applicable laws, (ii) respond to governmental inquiries or requests from public authorities, (iii) comply with valid legal process, (iv) protect the rights, privacy, safety or property of Playsee users, visitors, guests, employees or the public, (v) permit us to pursue available remedies or limit the damages that we may sustain; (vi) enforce our websites' terms and conditions, and (vii) respond to an emergency.
When do we share your personal data (legal bases for the data transfers):
Playsee may share the personal data we collect about you as follows:
When you give us consent (according to Art. 6 (1) (a) GDPR).
In Response to Legal Requests.
We may share your information in response to a legal request by the competent authority or to law enforcement officials or government authority if we have a good faith belief that the law so requires (according to Art. 6 (1) (c) and/or (f) GDPR).
Enforcement of Playsee Policy and Prevention of Harm.
We may access, share and preserve your information when we believe disclosure is necessary to detect, prevent and address illegal activity or the violation of the terms of the Playsee apps or website or this Privacy Notice, or to protect ourselves, the Playsee community and others (according to Art. 6 (1) (f) GDPR).
This includes to prevent spam, abuse, or malicious actors on our services, or to explain why we have removed content or accounts from our services; to address fraud, security, or technical issues; or to protect our rights or property or the rights or property of those who use our services. However, nothing in this Privacy Notice is intended to limit any legal defenses or objections that you may have to a third party, including a government’s, request to disclose your personal data.
Mergers and Acquisitions.
VI. Cross-Border Data Transfers
Some of the recipients of your personal data will be located or have relevant operations outside of your country and the EEA, where the data protection laws may provide a different level of protection compared to the laws in your jurisdiction and with regard to which an adequacy decision by the European Commission does not exist. We will take all necessary measures to ensure that transfers out of the EEA are adequately protected as required by applicable data protection law.
For recipients located outside of the EEA, some are located in countries with adequacy decisions pursuant to Art. 45 GDPR. In each case, the transfer is thereby recognized as providing an adequate level of data protection from a European data protection law perspective.
Other recipients are located in countries which do not adduce an adequate level of protection from a European data protection law perspective (in particular, the USA).By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses (2010/87/EC and/or 2004/915/EC) as referred to in Art. 46 (5) GDPR or other adequate means, which are accessible upon request under the contact details provided below, we have established that all such recipients located in countries which do not adduce an adequate level of protection from a European data protection law perspective will provide an adequate level of protection for the personal data and that appropriate technical and organizational security measures are in place to protect personal data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer (including our affiliates outside the EEA) is subject to appropriate onward transfer requirements as required by applicable law.
VII. How Long Do We Keep Your Information?
We keep your information only so long as required to provide the Services to you (i.e. for as long as you have an account at Playsee) and fulfill the purposes described in this notice. After this period of time, we erase your personal data from our systems and records unless we need to keep your personal data to comply with legal or regulatory obligations (including in particular statutory retention requirements) to which Playsee is subject. In addition, if a judicial or disciplinary action is initiated, the personal data will be stored until the end of such action, including any potential periods for appeal, and will then be deleted or archived as permitted by applicable law.
Should you wish to have your data erased from our Services, you can contact us directly via the contact details stated below. We will also delete your personal data or content should it violate our rules and Terms of Services.
VIII. Cookies and similar technology
We also use "web beacons" (also known as web bugs, pixel tags, or clear GIFS) which are small graphics with a unique identifier that may be included on our Services for example to deliver or communicate with cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on a user's hard drive or device, web beacons are typically embedded invisibly on web pages (or in an email).
Types of Cookies
We use the following types of cookies:
These are cookies that are essential to enable you to use the Services, for example moving around our websites and using their features (e.g. cookies that enable you to log into the Services).
These are cookies that help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third-party advertisers.
Unclassified cookies are cookies that we are in the process of classifying, together with the providers of individual cookies.
The types of cookies described above may be "session cookies" or "persistent cookies". Session cookies are only stored on your device whilst you are using the Services and are deleted when you log off from the Services or close your browser. Persistent cookies remain on your device for a period of time after you log off from the Services or close your browser.
Third Party Cookies
Some cookies may be placed by third parties when you use the Services as some third-party services providers that we engage (including third party advertisers) may place their own cookies on your hard drive or device. These cookies may provide information to those third parties about your browsing habits. Some also help to serve you with advertisements which are more relevant to you.
Although most browsers automatically accept cookies, you can change your browser options to stop automatically accepting cookies or to prompt you before accepting cookies. However, if you don’t accept cookies, you may not be able to access all portions or features of the Services.
List of Cookies Used
We use the following cookies in connection with our Services:
|beatSessionId||HTML||Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience.||Persistent||Necessary Cookies|
|beatSessionTs||HTML||Registers which server-cluster is serving the visitor. This is used in context with load balancing, in order to optimize user experience.||Persistent||Necessary Cookies|
|hs||HTML||Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.||Session||Necessary Cookies|
|TS#||HTML||Ensures security.||Session||Necessary Cookies|
|XSRF-TOKEN||HTML||Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor.||Session||Necessary Cookies|
|_ga||HTML||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||2 years||Statistic Cookies|
|_gat||HTML||Used by Google Analytics to throttle request rate||1 day||Statistic Cookies|
|_gid||HTML||Registers a unique ID that is used to generate statistical data on how the visitor uses the website.||1 day||Statistic Cookies|
|fedops.logger.sessionId||HTML||Registers statistical data on visitors' behaviour on the website. Used for internal analytics by the website operator.||Persistent||Statistic Cookies|
|svSession||HTML||Tracks a visitor across all wix.com sites. The information collected can be used to make advertisements more relevant for the visitor.||Persistent (2 years)||Functionality Cookies|
|SSR-caching||HTML||Indicates how a site was rendered||Session||Functionality Cookies|
VIIII. Your Rights
Pursuant to applicable data protection law, you have the following rights which you may exercise by contacting us as stated below:
Right of access
You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes – inter alia – the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.
You also have the right to obtain a copy of the personal data undergoing processing. For further copies requested by you, we may charge a reasonable fee based on administrative costs.
Right to rectification
You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure ("right to be forgotten")
Under certain circumstances, you have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.
Right to restriction of processing
Under certain circumstances, you have the right to obtain from us restriction of processing your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.
Right to data portability
Under certain circumstances, you have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another entity without hindrance from us.
Right to object
Under certain circumstances, you have the right to object, on grounds relating to your particular situation, or where personal data are processed for direct marketing purposes at any time to the processing of your personal data by us and we can be required to no longer process your personal data.
Moreover, if your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In this case your personal data will no longer be processed for such purposes by us.
Right to withdraw consent
If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.
Right to lodge a complaint with the supervisory authority
In addition to the rights set out above, you also have the right to lodge a complaint with the competent data protection supervisory authority.
X. Other Websites and Services
We are not responsible for the practices employed by any websites or services linked to or from our Services, including the information or content contained within them. Please remember that when you use a link to go from our Services to another website or service, our Privacy Notice does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party's own rules and policies. We are not responsible and do not have control over any third-parties that you authorize to access your User Content. If you are using a third-party website or service and you allow them to access your User Content, you do so at your own risk.
XI. Contact Details
If you have any questions about or in connection with this Privacy Notice or would like to complain about our handling of your personal data or exercise any of your rights, please contact us by using one of the following contact details:
Framy Inc. Hong Kong Limited Unit 705A, 7F, Far East Consortium Building 121 Des Voeux Road Central District, Hong Kong firstname.lastname@example.org
XII. Representative and Data Protection Officer
You may contact our data protection officer via the following options:
Framy Inc. Hong Kong Limited
Unit 705A, 7F, Far East Consortium Building
121 Des Voeux Road
Central District, Hong Kong