ClipSentry.com, an extension of AV Registry LLC, and Takedown Piracy, Inc., respects your privacy and is committed to protecting it through our compliance with the practices described in this privacy policy.

This policy describes our practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you visit our website located at www.ClipSentry.com (the “Platform”). This policy applies to the personal data collected by us through our Platform (including in email, text, and other electronic messages between you and us), offline, or through any other means, regardless of the country where you are located. This policy does not apply to personal data collected by any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Platform.

The Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for processing and storing your personal data. By engaging with our Platform, you accept and consent to the practices described in this policy. This policy may change from time to time (see Changes to our privacy policy). Your continued engagement with our Platform after any such revisions indicates that you accept and consent to them, so please check the policy periodically for updates.

1. Data we may collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, and username or similar identifier.
• Contact Data includes postal address, email address, and telephone numbers.
• Financial Data Financial Data is stored by our payment processor and you are encouraged to review their privacy policy and contact them directly for responses to your questions.
• Transaction Data includes details about subscriptions and billing history.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.
• Content Data includes raw videos submitted through the Platform (which are deleted immediately after processing), sample frames from the video, images, and all email communications.
• DMCA Data includes data needed for performing DMCA services, including studio name, stage name, keywords associated with brand, location of example content, and signature for DMCA authorization.
• Profile Data includes your username and password, information for authentication and account access, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our Platform, including the full Uniform Resource Locators (URLs); clickstream to, through, and from our Platform (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

If you fail 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. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

2. How we collect data about you

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us information about you by filling in electronic forms or by corresponding with us by phone, email, or otherwise. This includes information you provide when you create an account; subscribe to our service; submit videos to our system; request marketing to be sent to you; request information about our services; give us feedback; and when you report a problem with the Platform.
• Automated technologies or interactions. As you interact with our Platform, we may automatically collect technical data about your equipment, browsing actions, and patterns as specified above. We collect this information by using cookies, server logs, and other similar technologies (see Cookies and automatic data collection technologies).
• Third parties or publicly available sources. We may receive information about you if you visit other websites employing our cookies or from third parties including, for example, business partners; subcontractors in technical, payment, and delivery services; advertising networks; analytics providers; search information providers; data brokers; or data aggregators.

Cookies and automatic data collection technologies

Our Platform uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other Platform users. This helps us deliver a better and more personalized service when you use our Platform. It also allows us to improve our Platform by enabling us to:

• Estimate our audience size and usage patterns.
• Store your preferences so we may customize our Platform according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Platform.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, certain parts of our Platform may become inaccessible and certain features may not work correctly. Unless you adjust your browser settings to refuse cookies, our system will issue them.

Our website pages and emails may contain web beacons (small transparent embedded images or objects, also known as clear gifs, pixel tags, and single-pixel gifs) that permits us, for example, to count website page visitors or email readers, or to compile other similar statistics such as recording Platform content popularity or verifying system and server integrity.

Third-party use of cookies and other tracking technologies

Some content or applications on the Platform are served by third parties, including content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. They may associate the information collected with your personal data or they may collect information, including personal data, about your online activities over time and across different websites or other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control how these third-party tracking technologies operate or how they may use the collected data. If you have any questions about an application or other targeted content, you should contact the responsible provider directly.

3. How we use your personal data

We use information that we collect about you or that you provide to us, including any personal data:

• To present our Platform and its contents to you.
• To provide you with information, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To provide the support you have requested.
• To troubleshoot your issue and provide you with more effective customer service.
• To distribute alerts concerning service upgrades, special offers, white papers, updated information about existing and new services from ClipSentry.com, and to measure the effectiveness of these communications.
• To administer our Platform and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• To improve our Platform or services, marketing, or customer relationships and experiences.
• To protect our Platform, employees, or operations.
• To detect unauthorized access to the Platform.
• To make suggestions and recommendations to you and other users of our Platform about services that may interest you or them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may use nonpersonal data for any business purpose.

4. Disclosure of your personal data

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal data that we collect or you provide as described in:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business. Examples include payment processing, data analysis, email delivery, hosting services, customer service, and marketing efforts. We may allow selected third parties to use tracking technology on the Platform, which will enable them to collect data about how you interact with the Platform over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. For example, we use Google Analytics to help us understand how our customers use the Platform (you can read more about how Google uses your personal data here: https://policies.google.com/privacy). You can also opt out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AV Registry’s or Takedown Piracy’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by AV Registry or Takedown Piracy about our Platform users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data to third parties:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of AV Registry, and Takedown Piracy, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. Cross-border data transfers

We are based in the United States of America. For operational reasons we may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. Where we do so, and where we are required to under local law, we will put in place appropriate mechanisms to ensure that your personal data receives an adequate level of protection where it is processed.

If you are a Canadian resident or otherwise located in Canada, please note that personal data transfers outside of Canada may result in your data becoming accessible to foreign jurisdiction’s law enforcement or other authorities.

If you are a European Economic Area (EEA), United Kingdom (UK), or Switzerland resident or otherwise located in the EEA, UK, or Switzerland, please note that your information will be transferred outside of the EEA, UK, or Switzerland, including to the United States.

Please note that we have elected to not participate in the EU–U.S. or the Swiss—U.S. Privacy Shield Frameworks. Nevertheless, whenever we transfer your personal data out of the EEA, UK, or Switzerland, we will use reasonable efforts to ensure a similar degree of protection is afforded to it by ensuring that the recipient third party agrees to contractual clauses or other appropriate safeguards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA, UK, or Switzerland.

Except for data subjects located in the EEA, UK, or Switzerland, by submitting your personal data or otherwise engaging with our Platform, you consent to our transfer, storing, or processing.

6. Your personal data use choices

We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your data:

• Tracking technologies and advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Platform may become inaccessible or not function properly. For more information about the cookies we use, please see Cookies and automatic data collection technologies.
• Promotional offers from AV Registry or Takedown Piracy. We may use your Identity, Contact, Technical, Usage, and Profile 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, 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 services from us and you have not opted out of receiving that marketing. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a service agreement, or other transactions.
• Third-party marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates, or plug-ins enabling third-party features. If you follow a link to any third-party website or engage a third-party plug-in, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these third parties.

7. Accessing and correcting your personal data

You can access, review, and change your personal data by logging into the Platform and visiting your account profile page.

You may also send us a message through our contact form located at ClipSentry.com, on the main page, to request access to, correct, or delete any personal data that you have provided to us. In some cases, we cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or negatively affect the information’s accuracy.

8. Data security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all personal data you provide to use behind firewalls on servers employing security protections. We encrypt any payment transactions using SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to take care when providing information in public areas of the Platform, which any Platform user can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Platform. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the Platform.

9. Data retention

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal data so that it can no longer be associated with you. We reserve the right to use that anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

10. Children’s online privacy

We do not direct our Platform to minors and we do not knowingly collect personal data from persons under the age of 18 or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a person under the age of 18, we will delete it. If you believe we mistakenly or unintentionally collected information from or about a minor, please contact us through the contact form at ClipSentry.com

11. Withdrawing your consent

Where you have provided your consent to the collection, use, and transfer of your personal data, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us through the contact form located at ClipSentry.com. Please note that if you withdraw your consent, we may not be able to provide you with a particular service. We will explain the impact to you at the time to help you with your decision.

12. Do Not Track policy

Do Not Track (“DNT”) is a privacy preference that you can set in your browser. DNT is a way for you to inform websites and services that you do not want certain information about your webpage visits collected over time and across websites or online services. We are committed to providing you with meaningful choices about the information it collects and that is why we provide you the ability to opt out. But we do not recognize or respond to any DNT signals as the Internet industry works toward defining exactly what DNT means, what it means to comply with DNT, and a common approach to responding to DNT. For more information about DNT, visit www.allaboutdnt.com.

13. Your California privacy rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://clipsentry.com/ccpa.pdf.

California’s “Shine the Light” law (Civil Code Section 1798.83) permits our users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make that request, please contact us through the contact form located at ClipSentry.com.

Further, if you are a California resident and would like to opt out from the disclosure of your personal data to any third party for direct marketing purposes, please contact us through the contact form located at ClipSentry.com. If you opt out from permitting your personal data to be shared, you may still receive selected offers directly from us in accordance with California law.

14. Your Nevada privacy rights

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request through the contact us form located at ClipSentry.com. However, please know we do not currently sell data triggering that statutes opt-out requirements.

15. Your Canadian privacy rights

We comply with Canadian Federal and Provincial privacy laws and regulations, including the Personal Information Protection and Electronic Documents Act.

We will only use your personal information for the purposes intended and as detailed in this policy unless we have obtained your consent to use it for other purposes.

Residents of Canada are notified that the personal data they provide to AV Registry and Takedown Piracy, is stored in its databases outside of Canada, including in the United States, and may be subject to disclosure to authorized law enforcement or government agencies in response to lawful demand under the laws of that country.

You may withdraw your consent to our personal data collection, use, or disclosure, subject to legal and contractual restrictions.

You have the right to complain about our personal data handling practices.

If you need to contact us about your personal data or believe that we have violated your privacy rights, please contact us through the contact form, located at ClipSentry.com. You may visit www.priv.gc.ca for more information about your privacy rights.

16. Your EEA, UK, and Swiss privacy rights

If you reside in the EEA, UK, or Switzerland, the following terms apply to you.

Legal Basis for Processing

We may process your personal data because you have given it permission to do so (e.g., by sending data through the Platform’s contact or order forms), because the processing is in our legitimate interests and it is not overridden by your rights, or because AV Registry and Takedown Piracy needs to process your personal data to comply with the law.

Your Legal Rights

If you reside in the EEA, UK, or Switzerland, under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights may include the following:

• 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 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 services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at ClipSentry.com

No fee usually required

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 could refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

Right to file a complaint

If you reside within the EEA, you have the right to make a complaint at any time to the appropriate supervisory authority for your country of residence. See http://ec.europa.eu for those details.

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

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.

17. Changes to our privacy policy

We will post any changes we make to our privacy policy on this page. If the changes materially alter how we use or treat your personal data, we will notify you by email to the primary email address specified in your account or through a notice on the website home page. Please check back frequently to see any updates or changes to our privacy policy.

18. Contact information

Questions, comments, and requests regarding this privacy policy and our privacy practices are welcomed and should be directed to ClipSentry.com.