- explain what information we collect from you and how we collect it;
• explain how we use that information and our legal basis for doing so; and
• inform you of your rights and choices regarding this information.
1.2. Attention Seekers is committed to ensuring that your privacy is protected. We are committed to delivering the best experience when you use the Attention Seekers service, however you access it (via the URL www.attentionseekers.com and related URLs, via a mobile device, and all other current and future services) (the “Service”).
1.4. DATA CONTROLLER:
Attention Seekers Productions T/A Attention Seekers (07675879)
Unit 14, The Westworks, 195 Wood Lane , London , W12 7FQ , United Kingdom
Our websites include the following:
2.1. IF YOU ARE UNDER 13 YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS ATTENTION SEEKERS SERVICES AT ANY TIME OR IN ANY MANNER.
2.2. Protecting the privacy of young children is especially important. For that reason, Attention Seekers does not knowingly collect or maintain personal information (as defined by the United States Children’s Online Privacy Protection Act) from persons under 13 years-of-age. If Attention Seekers learns that personal information of persons under 13 has been collected on or through the Attention Seekers service, Attention Seekers will take appropriate steps to delete this information.
2.3. If you are the parent or legal guardian of a child under 13 who has become a Attention Seekers account holder, then please contact us at email@example.com to have that child’s account terminated and personal information deleted.
2.4. For residents of the EEA and residents of Brazil where the processing of personal information is based on consent, Attention Seekers will not knowingly engage in that processing for users under the age of consent established by applicable data protection law. If we learn that we are engaged in that processing with such users, we will halt such processing and will take reasonable measures to promptly remove applicable information from our records.
2.5. If you are under 18, you must have your parent or legal guardian’s permission to use the Service. Please have them read this Agreement with you.
2.6. If you are a parent or legal guardian of a user under the age of 18, by allowing your child to use the Service, you are subject to the terms of this Agreement and responsible for your child’s activity on the Service.
- THE TYPE OF INFORMATION WE COLLECT AND RECEIVE
3.1. There are broadly two categories of information we collect, being:
3.1.1. information that we must use in order for you to use the Service (“Necessary Data”); and
3.1.2. information that you can choose to supply which we will use to improve your experience on the Service (“Voluntary Data”).
In order for you to use the Service, we must collect the following information.
If you choose not to provide this information, you will not be able to fully utilise certain functions of the Service.
3.2. Registration Data. In order to use certain features of the Service, you will need to register an account. When registering you will be asked to provide an email address and create a display name and password. Please note that if you choose a username that includes or reveals your name or any other personal information, this will be publicly available on the Service. If you connect to the Service using credentials from a third-party application, website or service such as Facebook, Twitter, Twitch, or Google, you authorise us to collect your authentication information, being your applicable User ID.
3.3. Ongoing Data Usage. When you use the Service, we collect a variety of information relating to your ongoing user activity, including:
3.3.1. How you use the Service: the content you engage with, what’s going to be collected in terms of Service usage;
3.3.2. Technical data: the Internet Protocol (IP) of your computer, the types of device you are using to access the Service, the operating system and/or the software you are using to access the Service; and
3.3.3. Location information: we keep track of the domains from which you use the Service (but we cannot see a zip code or postal code unless you choose to explicitly provide this information to us).
3.4. Payment Data. Some content on the Service will be available to access free of charge. You may also choose to purchase content available on the Service for a fee, on a pay-per-view basis (a “PPV Event”) from a third-party ticketing provider.
3.4.1. If you purchase access to a PPV Event from a third-party ticketing provider, your credit or debit card information and other financial data which you submit will be collected by that third party ticketing provider and they will act as the data controller of such information. We will not hold any of your payment information or other financial data.
3.4.2. If you make a purchase by clicking on a third-party link provided on the Service, such third party may collect your credit and debit card information (and other necessary financial information) for the purpose of completing that transaction.
3.4.3. We may be provided with confirmation of your transactions with third parties accessed via the Service and, in some instances, such confirmation may include your personal information. Aside from such confirmations, the only information that we will collect from such third-party links as described in section 3.4.2 is: (a) the aggregate number of Attention Seekers users who utilised such third-party links; and (b) the number of purchases made by these generic users.
You can choose to supply us with the following information which we will use to improve your experience using the Service
3.5. Profile Data. Within your profile settings, you can choose to provide certain information, including a Country and city location, age and gender and a profile picture. Whether you choose to provide such information is entirely optional. If you do provide such information, this information may be made available to third parties in certain instances.
3.6. Connected Social Media Data. Within your profile settings, you may choose to connect to certain third-party applications, including social media networks. In such instances, we will collect the following information:
- HOW WE USE THE INFORMATION WE COLLECT AND RECEIVE
4.1. Consistent with the permissions you give us to collect the information, we will process the information for broadly two purposes, being: 1) to operate the Service and any associated services securely; and 2) to personalise and improve your experience using the Service and any associated services. We store your data for as long as is necessary to continue providing a great continuous experience on the Service or until requested otherwise by you.
4.2. Operating the Service securely.
4.2.1. We will use your Registration Data to verify and identify you when you log in to the Service and to operate your Attention Seekers account, preventing any unauthorised or illegal activity;
4.2.2. We will use your Registration Data to identify any contributions you make to the platform, be that your, views or other activity on the Service;
4.2.3. We will use your Ongoing Usage Data to make Service as interactive as possible and provide hosts and users with insights about viewing behaviour on the Service. Note that certain Ongoing Usage Data relating to how you use the Service will be made publicly available to other users of the Service by default from time to time;
4.2.4. In order so that we can comply with our legal obligations as a licensed provider of audio-visual content, we will use your Registration Data, Ongoing Usage Data and Profile Data (if you choose to provide it) to report to rights holders as part of our licensing framework;
4.2.5. We will use your Registration Data to respond to any comments or enquiries which you submit to us and to provide you with customer and technical support;
4.2.6. We will use your age to enable age restrictions where appropriate;
4.3. Personalising and improving your experience using the Service.
4.3.1. We will use your Registration Data, Ongoing Usage Data, Profile Data, Connected Social Media Data to customise your experience on the Service, such as providing tailored recommendations as to which hosts to follow, user profiles to follow, suggesting certain video content;
4.3.2. We will use your Registration Data, Ongoing Usage Data, Profile Data and Connected Social Media Data to customise any communications (including emails, push notifications or in-app messages) we send to you about the Service, including any changes to the Service. Such communications will be consistent with any permissions you have communicated to us, which are accessible in the within your account settings;
4.3.3. We will use your Registration Data, Ongoing Usage Data, Profile Data and Connected Social Media Data to ensure that any advertising or promotions on the Service (including for third party products and services) is relevant to you. We will never permit any third parties to contact you directly unsolicited, unless you have provided your express consent;
4.3.4. In addition to any specific grounds stated above, it is necessary for us to we process the above information in the manner described to ensure our legitimate interest of personalising and improving your experience using the Service, so that the service we are providing is always interesting to you.
4.3.5. We will also use data we collect to conduct aggregated and anonymised analysis of users’ viewing behaviour using the Service.
- SHARING INFORMATION
5.1. Sharing by you.
5.1.1. Information made public by default. Attention Seekers is about community. Therefore, certain information relating to your Registration Data, Ongoing Usage Data and Profile Data is always publicly available to ensure that the Service is as interactive as possible. [Your username, profile picture, OTHER PUBLIC COMMUNITY INFORMATION e.g. favourites / subscriptions] are made publicly available by default. [This information will automatically be accessible to others who view your Attention Seekers profile.] In the future, we may offer other interactive features which will make certain information publicly available;
5.2. Sharing by us.
5.2.1. Rights holders. At the heart of our work at Attention Seekers is the desire to create and share experiences, including original artistic works. The creators of these experiences deserve to be rewarded for their work. Therefore, we are committed to licensing from relevant rights holders. As part of our licensing framework, we are required to share certain information with rights holders. Such rights holders will use this information to evaluate how the audio content they are licensing is performing. We will share information on an aggregated and anonymised basis that does not identify you directly;
5.2.2. Commercial partners. Attention Seekers works with a range of commercial partners across a number of business purposes, including brand partnerships. We may share certain information with these commercial partners on an aggregated and anonymised basis in order to provide insights as to the use of the Service. We may also share certain information in order for those partners to contact you about services which you are interested in and to which you have provided your express consent;
5.2.3. Advertising. We share certain of your Ongoing Usage Data and Profile Data with advertising platforms on an aggregated and anonymised basis so that advertisements on the Service are tailored and relevant to you;
5.2.4. Service providers. We utilise a number of service providers to help us with a variety of important functions, including ensuring the security and operational functionality of the Service. We share certain information with these service providers in order so that they can provide these services to us and so that we can perform our obligations with you. Some of these service providers may be located outside of the European Economic Area;
5.2.5. Compliance with laws. We may disclose information to any courts, law enforcement bodies or governmental authorities in order to comply with our legal obligations and respond to any claims asserted against us. We will only disclose information to the extent we are legally obligated to do so;
5.2.7. Reporting. You can always report any suspected misuse of your personal information to us by emailing us at firstname.lastname@example.org and we will investigate your claim as soon as practicable.
- YOUR PREFERENCES
6.1. You can change and customise the communications which you receive from us in your settings. We will ensure that any communications (whether emails, push notifications) reflect your settings. However, as explained in section 5.1.1, certain information about your Ongoing Usage Data is made public by default.
- DATA TRANSFERS
7.2. Appropriate safeguards are in place, such as standard contractual clauses from the European Commission or a relevant supervisory authority, in order to ensure that any transfer of your personal data outside of the European Economic Area will be lawful and safe. Further information on these safeguards can be provided upon request by emailing us at email@example.com.
- YOUR RIGHTS
8.1. Users located in certain countries, including the European Union, are afforded specific rights regarding their personal information. Subject to eligibility, users in the European Union have the following rights:
8.1.1. Right to access. You may request to confirm whether or not we are processing your personal data. If we are, you can request a copy of your personal data, which we provide free of charge in the initial instance. Further copies may incur a reasonable administrative fee;
8.1.2. Right to data portability. The copy of your personal data we provide to you will be in a structured, commonly used and machine-readable format. You shall be entitled to transmit this personal data to another entity;
8.1.3. Right to erasure. You may request the erasure of your personal data;
8.1.4. Right to object. You may object, on grounds relating to your particular situation, at any time to processing of your personal data. If you are eligible to exercise this right, we will ensure that your personal data will no longer be processed for such purposes by us, unless we are required to do so by law or there are overriding compelling legitimate grounds for the continuation of the processing;
8.1.5. Right to rectification. You may ask us to change or update your personal data, especially if it is inaccurate;
8.1.6. Right to restriction of processing. You may request us to restrict the processing of your personal data in certain circumstances, such as if it is inaccurate or unlawfully held;
8.1.7. Right to withdraw consent. Where you have consented to the processing of your personal information by us, you may withdraw your consent at any time by modifying the relevant account settings or emailing us at firstname.lastname@example.org. Note that the withdrawal of your consent does not affect the lawfulness of any processing of your information by us before the withdrawal of your consent.
- COOKIES POLICY
9.1. What cookies are
9.1.1. A cookie is a small file which may be placed on your computer’s hard drive. Once the file is added, the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. There are “persistent” cookies, which stay on your device for a set period of time or until deleted, and “session” cookies, which expire once your web browser is closed.
9.1.2. There are also other similar technologies which help to identify your device when you return to an app or use a service, including pixel tags (transparent graphic images which indicate that a page or an email has been viewed) and mobile device identifiers.
9.1.3. We also integrate Software Development Kits, which is code that third party developers need to include to ensure the functionality of their services with the Service. We may use this technology, for instance, to allow you to connect your social media to the Service as described in section 3.6.
10.1. We are committed to ensuring that your information is secure. We have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect, including a security breach protocol. However, no security measures can ever be completely secure, therefore we cannot guarantee that these measures will stop any users try to get around the privacy or security settings on the Service through unforeseen and/or illegal means.
10.2. In the event that we believe that the security of your personal information in our possession or control may have been compromised or could be at risk, we will seek to notify you as promptly as possible. If we have your e-mail address, we may notify you by e-mail.
10.3. You should never disclose your account password to anyone else.
- THIRD-PARTY LINKS
- CONTACT US