Privacy Policy

Effective date: 30 Nov, 2019 SODREF LTD. S.A ("us", "we", or "our") operates website, mobile applications, OTT applications, and Connected TV applications (the"Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

COLLECTION OF INFORMATION
We may automatically collect information about the devices you use to access the App or our services and the content you view.The information we may automatically collect depends on how you access the services and content and includes, but is not limited to:Information related to the use and operation of the App; Device information (e.g., device identifier,advertising identifier, MAC address, carrier, operating system, IP address);Usage data associated with how you interact with the App, such as programming and viewership data and features used;Configuration data for any WiFi-enabled device you may use to access the App;Information related to your WiFi and cellular connections (e.g., data usage, network performance, signal strength,throughput, latency); andLocation information, including precise geolocation information, such as your service address and the location of a device in which you have installed the App.

Definitions:

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this PrivacyPolicy, we are a Data Controller of your Personal Data.
Data Processors (or Service Providers)
Data Processor (or ServiceProvider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected Personal Data
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to: Email address First name and last name Cookies and Usage Data We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any,or all, of these communications from us by following the unsubscribe link orinstructions provided in any email we send.

Usage Data
We may also collect information that your browser sends whenever you visit our Service or when youaccess the Service by or through a mobile device ("Usage Data"). ThisUsage Data may include information such as your computer's Internet Protocoladdress (e.g. IP address), browser type, browser version, the pages of ourService that you visit, the time and date of your visit, the time spent on thosepages, unique device identifiers and other diagnostic data. When you access theService by or through a mobile device, this Usage Data may include informationsuch as the type of mobile device you use, your mobile device unique ID, the IPaddress of your mobile device, your mobile operating system, the type of mobileInternet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data
We use cookies and similartracking technologies to track the activity on our Service and hold certaininformation. Cookies are files with small amount of data which may include ananonymous unique identifier. Cookies are sent to your browser from a websiteand stored on your device. Tracking technologies also used are beacons, tags,and scripts to collect and track information and to improve and analyze ourService. You can instruct your browser to refuse all cookies or to indicatewhen a cookie is being sent. However, if you do not accept cookies, you may notbe able to use some portions of our Service.

Examples of Cookies we use:
Session Cookies. We use Session     Cookies to operate our Service. Preference Cookies. We use     Preference Cookies to remember your preferences and various settings. Security Cookies. We use     Security Cookies for security purposes. Advertising Cookies.     Advertising Cookies are used to serve you with advertisements that may be     relevant to you and your interests.

Use of Data
Funplots Limited uses the collected data for various purposes: To provide and maintain our Service To notify you about changes to     our Service To allow you to participate in interactive features of our Service when you choose to do so To provide customer support To gather analysis or valuable     information so that we can improve our Service To monitor the usage of our Service To detect, prevent and address technical issues To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
If you are from the European Economic Area (EEA), Funplots Limited. legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.  Funplots Limited. May process your Personal Data because: We need to perform a contract with you You have given us permission to do so The processing is in our legitimate interests and it's not overridden by your rights To comply with the law.

Retention of Data
Funplots Limited. will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Funplots Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retainthis data for longer time periods.

Transfer of Data
Your information, including Personal Data, maybe transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Funplots Limited, will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data
Business Transaction If Funplots Limited. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy. Disclosure for Law Enforcement Under certain circumstances, Funplots Limited may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency). Legal Requirements Funplots Limited may disclose your Personal Data in the good faith belief that such action is necessary to: To comply with a legal     obligation To protect and defend the     rights or property of Funplots Limited. To prevent or investigate     possible wrongdoing in connection with the Service To protect the personal safety     of users of the Service or the public To protect against legal     liability

Security of Data
The security of your data is important to us,but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

"Do Not Track" Signals
We do not support Do Not Track("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Funplots Limited  aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at admin@funplots.co In certain circumstances, you have the following data protection rights:

- The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have  the right to object to our processing of your Personal Data.
- The right of restriction. You  have the right to request that we restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have  on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Funplots Limited relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Service Providers
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. We may allow other companies,called third-party ad servers or ad networks, to serve advertisements within our services. These third-party ad servers or ad networks use technology to send the advertisements and links that appear on our site and apps. We do not provide any personally identifiable information to these third-party ad servers or ad networks without your consent or except as part of a specific program or feature for which you will have the ability to opt-in or opt-out.

Analytics
We may use third-partyService Providers to monitor and analyze the use of our Service.Google AnalyticsGoogle Analytics is a webalytics service offered by Google that tracks and reports website traffic.Google uses the data collected to track and monitor the use of our Service.This data is shared with other Google services. Google may use the collecteddata to contextualize and personalize the ads of its own advertising network.For more information on the privacy practices of Google, please visit theGoogle Privacy Terms web page: https://policies.google.com/privacy?hl=en

Advertising
We may use third-party advertising companies to serve ads when you visit our Service. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please contact us.

Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services. 

Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on ourService, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.