Last updated: May 25, 2018
Welcome to Multimedia Group Telecom!
We, Multimedia Group Ltd. and our corporate affiliates (“Multimedia Group”, “We” or “Us”), highly value and respect your privacy and therefore we are investing great efforts and resources in order to optimize your privacy.
By accessing or using our Services, you agree to this Policy and to our Terms of Service. Therefore, please take a moment to familiarize yourself with the Policy before using our Services. If you do not agree to this Policy or Terms of Service, you shall not access or otherwise use our Services or any information contained herein.
As a user-generated live video broadcasting platform, our Services allow you to submit, upload, post or broadcast content (including without limitation information, video, sounds, images, photos, clips, musical works, works of authorship, usernames, data, notes, text, documents, files, messages, signs, symbols, icons, drawings, animation, graphics, charts, designs, scripts, code, audio, comments, software, applications, links, and other materials) via Facebook Live.
Naturally, anything that you or other users submit, upload, post, broadcast or otherwise make available, to Us or to others, on our Services, may be “personally identifiable” (meaning it can be used to specifically identify you as a natural person) (“Data ”) or “non-personally identifiable information” (meaning it can’t be used to specifically identify you). We process both types of information, and combinations of both types, as described above.
We advise you to exercise caution and common sense when sharing, submitting, uploading, broadcasting or otherwise using the Services.
We will collect the information that may identify you on the basis of your consent or without your consent if:
the Data is required for rendering the Services to you;
the Data is required for complying with legal obligations, such as a court order or in response to the authorities;
the Data is required for Our legitimate purposes (or the legitimate purposes of those acting in Our behalf) which will be broadly described below under the “How We Use the Data We Collect and Store and for what Purposes” section.
If you reside or are using the Services in a territory governed by privacy laws which determine that consent is the only legal basis for the processing of the Data, by using the Services you hereby consent to the processing of the Data for all purposes detailed in this Policy.
What Data we collect?
Information you provide us or give us permission to obtain.
Since our Services are rendered on Facebook’s platform, in order to use the Services, you must register through your Facebook account. By doing so, you provide us with all information publicly available at your Facebook account (e.g., your name, profile picture or its URL, friends list, Facebook ID number/token, gender, your birthday or age range and email address). Please note that you can change the privacy settings in your Facebook account at any time to limit the information provided to us.
Please note that when you contact us, we record and process your inquiry and all information you provide therewith.
Any information you provide us is provided by you voluntarily. However, certain information is required in order for you to register and enjoy the full benefits of our Services.
Information we collect from your use of the Services.
In the course of your use of our Services, we may collect and process additional information which is necessary for rendering our Services to you or for the fulfillments of other purposes that will be described below.
Technical information – when you use our Services, your device communicates with our servers. This communication generates a transfer of technical data about your devices. We may automatically collect that information, including your Internet Protocol (IP) address, the type of the device you are using our Services on, hardware model, operating system version, your device and hardware settings, unique device identifiers, and crash data.
When you access the Services through our mobile App, we may also collect information from your mobile device. This collection of information is subject to your approval upon installation of the App and you can always revoke your consent to our ongoing ability to collect information from your mobile device by changing the settings on your mobile device, if your device offers that option, or by simply deleting our App from your mobile device.
Further, your use of the Services is documented in a log. That means that we are recording how you used our Services, the frequency and scope of your use of the Services, the content of your broadcast, pages you visited, your communications with other users and third parties, access times, cookie data, the referring website address, and additional related metadata, such as the time, date, and place of your broadcasts.
Broadcasts – as part of our services, we allow you to store and access your previous broadcasts. In order to do so, we store the video of the broadcasts in our servers. These videos may contain personal information – such as your image, your voice, and your surroundings – which may identify you, as well as other individuals who may appear in your broadcast. You are solely responsible for obtaining the consent of any and each person that appears on your broadcast, for such storage.
In addition to the videos of the broadcasts, we also collect and store all related texts, logo, pictures and any other information you have shared with the viewers during the broadcast.
Aggregated information – we may also gather statistical and aggregated information originating from our users which may be combined with additional non-identifiable information collected from other sources, regarding the use of the Services. This information will be anonymous and will not allow, by reasonable means, to identify – or to be attributed to – a specific user.
We will use this information for the purposes of internal research and development, and we also may share it with our business partners, affiliates or other third parties including advisors, advertisers and investors, for the purpose of conducting a general business analysis.
How We Use the Data We Collect and Store and for what Purposes
We will store and process your information for the following purposes:
Ongoing operation and performance of the Services – for example, when we store your registration information and/or Facebook login and account settings, we are able to save you the trouble of having to fill in information and set up your account every time you access and use our Services.
Support and communication with users – we collect information (e.g. user ID, name, Facebook Messenger, email, broadcast information) which allows us to detect and fix technical problems, as well as identify and contact you in order to provide the most efficient support.
Improvement of the Services and user experience – we seek to constantly improve the Services and enhance the user experience. Therefore, we use the Data to help us to better customize and display the content, website and mobile App experience.
Marketing or advertising our Services – we collect and analyze information which allows us to better understand the effectiveness of our marketing efforts. Depending on your notification settings, we may send you newsletters, updates, marketing materials and other information that may interest you by e-mail and/or via mobile devices.
Our Internal Course of Business – like any business, we use the Data to manage our daily conducts, such as using your PayPal payment details, payment history, your name and email address, for billing purposes.
Compliance with the law –we collect information necessary to protect Multimedia Group and its users and in order to comply with all applicable laws, regulations and legal processes, protect your privacy, prevent illegal activities, enforce applicable terms of service and protect Multimedia Group and Multimedia Group users’ rights.
Additional legitimate interests including:
Preventing and responding to fraud, inappropriate use or abuse of the Services;
Preventing or addressing technical or security issues;
Fulfilling our commitments to our partners or other third-parties;
Internal research for the purpose of evaluating the use of the Services, developing new features to our Services and improving user experience;
Marketing to you or advertising of our Services;
Ensuring the protection of Our rights, security and property (and those of our partners, contractors and users);
Various legal purposes, such as the establishment, exercise or defense of a legal claim.
Sharing of information
Your Sharing of Data
Our Services, specifically the broadcasting, are naturally aimed for sharing. This is most significantly reflected by the fact that we render the Services on a social network platform.
However, this does not mean that you have to share every use of our Services. You can always control what you share and with whom you share it before any broadcast simply by choosing the preferred option in the “Host a Broadcast” screen or by changing your Facebook account settings.
Our Sharing of Data
We will not share your Personal Information with third parties, except in the following instances:
When we have received your permission.This includes sharing information as described in this Policy or otherwise with other services (like Facebook) when you have chosen to link those services to your account or publish your activity on our Services to them.
When we engage third parties to process Data on our behalf.Such third parties’ use will be subject to our explicit instructions and in compliance with this Policy. For example, we may provide Data to a contractor who will provide support on our behalf.
With our affiliates.This relates to entities that are legally part of the same group of companies that we are part of, or that become part of that group.
In case of a change of control.If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, we may transfer the information to our new owner.
As a response to a legal request if we believe that we are required to do so by any applicable law; or (ii)when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud and other illegal activities; enforce this Policy or our Terms of Service, including in order to investigate potential breaches thereof; protect our rights, property or safety, or those of our users or members of the public from harm, as required or permitted by applicable law; and prevent death or imminent bodily harm.
Non-Personally Identifiable Information . We may also share aggregated or non-personally identifiable information that we collect and share as broadly described above under “information we collect” section.
What are your rights regarding the Data?
Access to the Data – since most of your personal information is provided by you, mainly through your Facebook account, you have full access to your Data. However, you may request a copy of the Data and we will provide it to you subject to applicable law and as long as it does not infringe third parties’ rights.
Rectification of the Data – you can change or amend your information any time by editing your Facebook profile. You are responsible to make all necessary changes to correct any information in your account which is inaccurate, in complete or outdated. Please keep in mind that false, incorrect, or outdated information may prevent you from registering to our Services and impair our ability to provide you with Services. If you have a reason to believe we possess incorrect Data relating you, you may request the amendment of such Data.
Deletion of Data – you may contact us at all times with a request to delete your Data. We will comply with this request and delete any Data which is associated with you to the extent possible. However, you should be aware that we use backup systems in which your data is stored without the ability to delete it immediately upon request. Therefore, we may require an additional short period of time until we are able to fully delete all traces of your Data.
Nonetheless, for legal reasons, organizational reasons or in order to prevent fraud, we may retain certain specific information relating to you. In any event, your request for deletion will be recorded and will not be deleted.
In addition, under certain circumstances you may have the right to object to the processing of the Data and to export certain Data to another service.
How we retain your Data
We will retain the Data only as long as it is required for the fulfillment of the purposes stated in this Policy. Some Data will be deleted automatically – e.g. if it is no longer required for the fulfillment of the purpose for which it has been collected or Data that is no longer relevant or if you have terminated your account– and some Data will be deleted upon your request – e.g. Data that you directly provided to us and wish to erase.
Certain regulatory, legal or organizational requirements may require the retention of specific Data for longer periods of time. This includes:
Data which is required to prevent fraud or abuse of our Services;
Data which is required for our internal security purposes;
Data which needs to be retained for bookkeeping and accounting purposes, in order to comply with legal or regulatory requirements or to exercise any legal right.
We will retain the minimum Data required for those purposes.
How Do We Secure Your Information?
We consider data security a top priority and we do our best to keep your Personal Information secure. For that purpose, we:
Encrypt all of our services using SSL.
Employ firewalls and intrusion detection systems.
Practice administrative, technical, and physical security procedures to help protect the information you provide us.
Although we take organizational, technical and administrative measures to protect your Data, no method of transmitting or storing electronic data is ever completely secure. Therefore, you cannot reasonably expect and we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse. Please be aware that we may use third-party cloud service providers that provide hosting, data storage and other services pursuant to their standard terms and conditions that are generally non-negotiable, and accordingly, we may be unable to impose contractual obligations on them with respect to the measures they use to protect Personal Information.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below.
External Links and Third Party Services
Transfer of Data
By using the Services you hereby provide your consent to the transfer of your Data outside of your country.
If you reside in, or are accessing the Services from, the European Union, you should know that most of the processing of your Data takes place within the European Union or in territories recognized by the EU Commission as providing adequate protection to your Data.
The above notwithstanding, we may transfer, process and store your Data also in territories which have yet to be recognized by the EU Commission as providing adequate protection to your Data. However, we will do so only after we have verified that your Data will remain protected, and by using the Services you hereby consent to such transfer, processing or storage.
In addition, please note that your information is stored on servers maintained by third party service providers. We ensure the compliance of these third parties with the requirements of the appropriate privacy protection regulations.
Protection of Children’s Privacy
Our Services are not directed to children under the age of 16.
IF YOU ARE UNDER 16 YEARS OF AGE, YOU MAY NOT USE OR ACCESS THE SERVICES AT ANY TIME OR IN ANY MANNER.
Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or maintain Personal Information from persons under 16 years of age. If we learn that Personal Information of persons under 16 years of age has been collected by us on or through the Services, we are committed to take the appropriate steps to delete such information.
If it comes to our attention through reliable means that a registered user is a child under 16 years of age, we will cancel that user’s account and/or access to the Services.
Changes to the Policy
We are constantly seeking to improve our privacy practices. Accordingly, we may amend, change, update or modify this Policy from time to time.
Any such change, update or modification will be effective immediately upon posting and will apply to any cause of action arising after the effective date of the change.
You are solely responsible for checking the Policy for updates or changes, and we recommend you do so on an ongoing basis to ensure that you agree with its updated terms. You can easily discern if any changes have been made in the Policy by checking the “Last Updated” date at the top of the Policy.
If we make material changes in the way we process information or in the purposes for which we process the information, we will notify you by email or through the App.
Your continued use of our Services following the posting of changes to this Policy or receipt of notice, whichever occurs first, means that you accept those changes.
You can address any question or concern you may have with regard to this Policy, or if you have a reason to believe that your privacy or the privacy of your Data has been compromised, to our data protection officer by sending an email to: [email protected]
You can also contact your local data protection authority for any inquiry or complaint.