I. Objective and Scope

PavoTV Ltd ("we", "us", "Company") values the trust placed in us by data subject ("you", "your", "user", "subscriber") and therefore, we follow the highest standards of privacy guidelines to protect the information shared by you with us.

This Privacy Policy ("Privacy Policy") governs the use of Personal Information shared (as defined below) with or collected by Company from the users or subscribers of our online services in Singapore including the 'PavoTV' SVOD service and our PavoTV or &TV branded Websites and apps (the 'PavoTV Services').

This privacy policy describes the usage of information provided or collected on the sites and applications where this privacy policy is posted. We follow this privacy policy in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain services or regions. Those terms are to be read in combination with this policy.

Please keep in mind that when you provide information to us on a third-party site or platform (for example, via our applications like social media login the information we collect is through those third-party sites linked with our applications is covered by this privacy policy, and the information the third-party site or platform collects is subject to the third-party site or platform's privacy practices. Privacy choices you have made on the third-party site or platform will not apply to our use of the information we have collected directly through our applications. Please also keep in observance that our sites and applications may contain links to other sites not owned or controlled by us and we are not responsible for the privacy practices of those sites. We encourage you to be aware when you leave our sites or applications and to read the privacy policies of other sites that may collect your personal information.

All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Use.

This Privacy Policy should be read in conjunction and together with the Terms of Use applicable to the PavoTV Services you are using.

II. User Consent

By using PavoTV Services (for example, when you register for an account, purchase a service, enter a contest or promotions, communicate with us, on our sites or applications), you agree to provide consent to our collection, use and sharing of your personal information as described in this policy. By using PavoTV services you also consent to sharing of your Personal Information with third parties for marketing and advertising purposes. In case of any roaming user profile or if you are a traveller visiting various countries around the world and avail PavoTV5 services, then we will consider the country of registration as your primary country and the consents obtained at the time of registration will be valid for your processing of personal information.

III. Collection and Use of Personal Information

'Personal Information' or 'PII' is defined as any information that identifies (whether directly or indirectly) to a particular individual or natural person, such as the individual's name, postal address, email address, and mobile number indicating to that particular person or is identifiable. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.

IV. Information you provide to us

We may ask for and collect the following personal information about you when you use the PavoTV Service and without this information we may not be able to provide you with all the requested services;

• First/Last Name
• Email id
• Primary Phone No/Mobile No.
• Country
• Date of Birth
• Gender
• V. Information we collect automatically
• We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your computer or other device used to access our service(such as smart TVs, mobile devices, tablets and certain streaming devices). The information includes:
• Activities on the PavoTV Services such as type of content, watch history, search queries etc.
• Device information like device id, device model etc. and other unique identifiers
• Your interactions with our email, customer care and messaging platform.
• Geo-location information through IP addresses*,
• Advertising identifiers, such as those found on mobile devices, tablets, and devices that include such identifiers (for example the Identifiers for Advertisers (IDFA) on iOS devices and GAID on Android devices) and certain streaming devices.;
• Information collected via the use of cookies and other technologies;(You can read more about how we use cookies in our (Cookie Policy).

*Note: The IP address that we collect automatically is used for transaction/billing purpose for the user willing to pay for using PavoTV Services. Basis the IP address we also capture the geo location from where the user is trying to access content. This information is further used internally for taxation purpose to identify from which geo location (country) the user has have availed the services.

VI. Inferred Information through usage and log data

We may track certain information about you based upon your behaviour on the PavoTV Services. We use this information for conducting internal research on our users' demographics, devices, interests, and behaviour to better understand, protect and serve our users. This information is compiled and analysed on an aggregated basis. This information may include the platform that you just visited (whether this platform is on PavoTV Services or not), which platform you next visit, your computer browser information.

We may also collect Your Information to track user behaviour and preferences for internal analytics and research. We may also use your information:

(i) To evaluate Your interest for various genres of content, services, offers;

(ii) To perform analytics and conduct customer research, to determine your interest, for identifying Content that generate sales and to analyse traffic patterns

If you choose to post messages on social media accounts, message boards, chat rooms or other message areas or leave feedback, we will collect that information you provide to us. We retain this information as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law.

If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the PavoTV Services, we may collect and store such information.

We identify and use Your IP address to help diagnose any problems with our server, and to administer Company.Your IP address is also used to help identify you and to gather broad demographic information to customize your experience on the PavoTV Services.

We will occasionally ask you to complete optional online surveys. These surveys may ask you for contact information and demographic information (like zip code, age, etc.). We use this data to tailor your experience on the PavoTV Services, providing you with content that we think you might be interested in and to display content according to your preferences.

VI. Information we collect through third parties

Third party services

If you link, connect or login through you the Company account with a third party service i.e. Google, Facebook and Twitter they may send us information such as your registration and profile information from the service. Below mentioned are the information getting collected through social platforms such as:

• Facebook - Public information, Name, Email id, friend list
• Google - Email id
• Twitter - Email id, twitter handle, read tweets from your time line and see who the user is following.

Billing Information

Based on Your purchase of a subscription package, our payment gateway partners including payment via Apple iTunes and Samsung Smart Pay may collect information with respect to your credit/debit card details or other bank account details along with your billing address. This information is stored by our payment gateway partners. For instance, the PavoTV Services will be using third party payment gateway partners to process and facilitate the payment of your subscription fee to the PavoTV Services for providing you access to the subscription. Please note that the PavoTV Services do not directly collect any financial information such as credit card or debit card or net banking details from you. Such payment gateway partners are not controlled by us. When you visit such payment gateways you do so at your own risk. These payment gateways may have their own privacy policies in place, which we recommend you review if you visit any such payment gateways. We do not assume any responsibility or liability for such payment gateways, the content of such payment gateways and their privacy practices, nor do we endorse them. We encourage you to familiarize yourself with the privacy statements provided by such payment gateways prior to providing them with information about you or entering into any transactions with them.

While transacting with these payment gateways, you may provide your financial information including without limitation your bank account details, credit card account details or your details pertaining to any payment settlement or pre-paid instrument service provider. You understand, agree and acknowledge that the PavoTV Services never receive your financial and payment information from these payment gateways. Your Personal Information, Sensitive Personal Data or Information and financial information will be dealt by these payment gateways in accordance with their respective privacy policies and other terms and conditions and Company shall not be liable, accountable or responsible for Your Personal Information, Sensitive Personal Data and Financial Information which you provide to these payment gateways.

Auto renewal Subscription

When you chose any subscription or paid service, we or our payment gateway provider may collect your purchase, address or billing information, including your credit card number and expiration date etc. However when you order using an in-app purchase option, same are handled by such platform providers. The subscriptions or paid Services may be on auto renewal mode unless cancelled. If at any point you do not wish to auto-renew your subscription, you may cancel your subscription before the end of the subscription term. We do not capture/store any personal payment information with us.

VII. Purposes and Lawfulness of processing

We will only collect and process personal data about you where we have lawful basis. Lawful basis on which we would process our personal information includes obtaining consent from you for processing your personal information or processing for “legitimate interests” where processing is necessary by us to provide you with customer support or process your data for providing premium services (For e.g. processing your information by our payment gateway service providers).

We use information to provide, analyse, administer, enhance and personalize our service and marketing efforts, to process your registration, your orders, payments, and to communicate with you related to below mentioned points. For example, we use information to:

• determine your general geographic location, provide localized content, provide you with customized and personalized viewing recommendations for movies and TV shows we think will be of interest to you, determine your Internet service provider, and help us quickly and efficiently respond to inquiries and requests;
• analyze and understand our audience, improve our service (including our user interface experiences) and optimize content selection, recommendation algorithms and delivery;
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforcing our terms (such as determining free trial eligibility);
• communicate with you concerning our service (for example by email, push notifications text messaging, and online messaging channels), so that we can send you news about Company details about new features and content available on the PavoTV Services, and special offers, promotional announcements, and consumer surveys, and to assist you with operational requests such as password reset requests.
• notify you about changes in terms of service.
• allow you to participate in interactive features offered through our Services.
• carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, charge back and collection.

We may also use your information to contact you about our own and third-party services that may be of interest to you.

VIII. Disclosure to third parties

General Disclosure

At times the Company may make certain personal information available to strategic partners that work with the Company to provide service, or that help the Company market to customers. For example, when you purchase and activate subscription, you authorize the Company to exchange the information you provide during the activation process to carry out a service. If you are approved for service, your account will be governed by the Company's privacy policy. Personal information will only be shared by the Company to provide or improve our service and marketing aspects; it will not be shared with third parties for their marketing purposes.

We do not share your personal information with Companies, organizations, or individuals outside of Company except in the following cases:

Advertising

We use third-party advertising companies to serve ads when you visit or use our website, mobile application or services. These companies may use information (not including your name, address, email address or telephone number or other personally identifiable information) about your visits or use to particular website, mobile application or services, in order to provide advertisements about goods and services of interest to you.

Services may include links to other websites or applications. Such websites or applications are governed by their respective privacy policies, and are beyond our reasonable control. Once you leave our server (you can recognize your location by checking the URL in location bar on your browser), any kind of information provided by you is governed by the privacy policy of the operator of the applications/website(s) you are visiting. Their policy may differ from ours. If you can't find the privacy policy of any of these applications/websites via a link from the application's homepage, you should contact the application owner(s) directly for more information.

Presentation of information to our advertisers for helping them to understand our audience(s) and to know the value of advertising on our websites or applications, is usually in form of aggregated statistics on traffic to various pages/content within our websites or applications.

Service Provides

PavoTV Services may provide links to various third-party websites that may collect Your Personal Information. Use of Your information collected by such third-party platform will be governed by the privacy policy in such third-party platform. Company has no control on the operation of such third-party websites and you may share information with such third party at your sole risk. Company shall not be liable to you for any misappropriation of Your Personal Information by such third party.

We may share non-personally identifiable information publicly and with our partners - like publishers, advertisers, developers, or rights holders. For example, we share information publicly to show trends about the general use of our services. We also allow specific partners to collect information from your browser or device for marketing/promotions and measurement purposes using their own cookies or similar technologies.

Promotional Offers

We'll share or disclose your personal information outside of ATS. For example, providing E-mail related services such as marketing newsletters, promotions and offers.

Business Transfers

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 and any other appropriate confidentiality and security measures. For example, we use service providers to help us with customer support.

Legal

In the event of any requirement by court order, government or quasi-government agency to disclose Your Personal Information, We will disclose information as may be legally required. We may also disclose Your Personal Information if we, in the good faith believe that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.

In the event Company is merged with or acquired by another company, we and our affiliates may share your personal information, wholly or in part, with another business entity.

IX. Your Controls and Choices

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your personal information. In accordance with applicable law, your controls and choices may include:

Managing Your Information

You can access and update some of your personal information through your account settings. If you have chosen to connect your Company account to a third-party application, like Facebook, Google or Twitter, you can change your settings and remove permission for the app by changing your account settings. You are responsible for keeping your personal information up-to-date. The Company will send you periodic reminders via e-mail to maintain the accuracy of your personal information.

Rectification of Inaccurate or Incomplete Information

You can ask us to correct inaccurate or incomplete personal information concerning you (this is the information which you cannot update yourself within your Company account) by sending us an e-mail

Data Retention and Erasure

We retain your personal information as long as necessary for the performance of the contract between you and us to comply with our legal obligations. If you no longer want us to use your information then you can request that we erase your personal information and close your Company account. Please note that if your request for the erasure of your personal information;

• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Company account for fraud or safety reasons, we may retain certain information from that account to prevent that user from opening a new account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, we may keep some of your information for tax, legal reporting and auditing obligations.
• Because we maintain copies of the Company to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

Withdrawing Consent

For withdrawing your consent at any time during the tenure of your services with us, you may choose to do so by sending us an e-mail. We shall review your request and may ask you to verify your identity. Post verification we will withdraw the consent for which request was made by you and stop any further processing of your personal information.

X. Children's Privacy

Company is not intentionally designed for or directed at persons less than 21 years of age. Company does not knowingly permit any person who is under 21 years of age to register with the services or to provide any other personally identifying information. If Company becomes aware that any personally identifiable information of persons less than 21 years of age has been collected on the Company without verified parental consent, then Company will take the appropriate steps to delete any such information and notify the parent.

However, we consider it the responsibility of parents to monitor their children's use of our services. Nevertheless, it is our policy not to collect and process any personal information from children below 21 years of age or offer to send any promotional materials to persons in that category. Company does not seek or intend to seek or receive any personal information from children. Should a parent or guardian have reasons to believe that a minor has provided company with personal information without their prior consent, please contact our customer support team to ensure that the personal information is removed from the Company.

XI. Data transfer, storage & processing globally

We operate globally and may transfer your personal information to individual companies of the Company affiliated companies or third parties in locations around the world for the purposes described in this privacy policy. Wherever your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information.

XII. Respecting your contact preferences

Company is committed to complying with the Do Not Call (DNC) provisions. We have always been mindful of engaging our customers in a more targeted and relevant way.

We may send marketing messages to your Singapore telephone number if:

• you have given us consent, OR
• you have not registered with the national DNC Registry, OR
• the sending of such messages is permissible under applicable laws and regulations.

Our marketing messages aim to update you about our exclusive offers, rewards programme and special deals from our preferred partners and advertisers.

If you wish to continue receiving such messages or to opt out, you can indicate your preference at any time via sending an email to our customer support team.

Please note that after opting out, you may still continue to receive non-marketing messages, such as product updates and service notices as permitted under applicable local laws and regulations.

XIII. Security and compliance with laws

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Company account credentials have been lost, stolen, altered, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us by contacting our customer support team.

XIV. Change in Policy

This Privacy Policy is subject to change from time to time. We reserve the right, at our sole discretion, to modify the terms of this Privacy Policy from time to time in order to ensure compliance with applicable laws (“Updated Terms”). The Updated Terms shall be effective immediately and shall supersede these the terms of this Privacy Policy. We will not be under an obligation to notify you of any changes to this privacy policy except if the changes made to the policy significantly affects your rights or as may be required by law. You shall be solely responsible for reviewing the Privacy Policy from time to time for any modifications. By continuing to use Company after the updated Terms have been published, you affirm your agreement to the updated terms.

XV. Contact information

If you require any information or clarification regarding the use of your personal information or this privacy policy or grievances with respect to use of your personal information, please email us at [email protected]