Privacy Policy

This Privacy Policy describes how caly-film LLC and its subsidiaries and affiliates, including but not limited to caly-film USA LLC and Locals Technology LLC (collectively, “caly-film,” or “we” or “us” or “our”) collect, use, and share Personal Information. This Privacy Policy applies to all services offered through our mobile applications, platforms, and websites (collectively, the “Services”), and to any Personal Information obtained from website visitors and users who provide us with their Personal Information in connection with the Services we provide directly to those users.

We take your privacy seriously. We encourage you to review this Privacy Policy whenever you access our Services or otherwise interact with us to stay informed about our data privacy practices and the choices available to you. By using the Services, you agree to this Privacy Policy. caly-film may choose to update or revise this Privacy Policy from time to time, with or without notice to you. Any changes to this Privacy Policy will be noted by updating the date at the top of the policy. If the changes are substantial, we may provide a more prominent notice. If you have any questions or concerns, please contact us.

1. INFORMATION WE COLLECT
We collect your Personal Information based on the purpose for which you provide it to us. “Personal Information” includes any information that we collect about you that, alone or in combination with other information, can be used to identify you, such as a personal identifier (e.g., name, email or postal address, phone number, etc.), online identifiers, or inferences about your preferences. For the purpose of this Privacy Policy, Personal Information also includes “Personal Data,” as defined under the General Data Protection Regulation (“GDPR”) or other applicable international data protection laws.

We collect Personal Information in the following situations, as applicable:

When you browse our website or use our Services;
When you voluntarily provide information directly to us (e.g., when you sign up to become a registered user of our Services or provide content to our platforms); and
When you register to join caly-film by logging into an account through a third-party Social Networking Site ("SNS"). Please be advised that if you decide to create your user account by logging into an SNS via the Services, you are using the Personal Information you have already provided to the SNS (such as your "real" name, email address and other information you make publicly available via the SNS) to create your user account on our Services. As a result, the information we collect may depend on the privacy settings you have enabled with the SNS. Please consult that SNS's privacy policy for additional information on their privacy practices.
We collect (or have collected during the preceding 12 months from the date of this Policy) Personal Information that generally falls within one or more of the following categories:

Direct Identifiers. We collect identifiers such as your real name, alias, email address, phone number, account username and password, photographs, biographical information, and other similar information.
Protected Classifications. We collect age information based on date of birth.
Internet Activity. We collect usage and log data about devices you use to access the websites, such as browser type, device manufacturer, operating system, domain name and IP address, the webpage you were visiting before you came to our Services, the webpages of our Services that you visit, information you search for on our Services, access times and dates, and other statistics from all website visitors (“Automatically Collected Information”). Our mobile and connected television applications (“App”) provide our users with access to and the use of the Services from their mobile devices or television. We may receive your mobile device model and software version, which allows us to improve the performance of our App.
Inferences drawn from other Personal Information. We collect Personal Information reflecting personal preferences of users.
2. HOW WE USE YOUR INFORMATION
We may also use the Personal Information we collect as otherwise disclosed to you at the point of collection, or for any other purposes with your consent. We use your Personal Information in the following circumstances:

Account registration. We create your user account for your use of the Services based upon the Personal Information you provide. You may review, update, correct or delete the Personal Information in your account by editing your profile via the Services. If you choose to completely delete all of your Personal Information, your account may be deactivated and our Services may not be available to you. You may also contact us at the email address listed at the bottom of this Privacy Policy with any request to update, correct, or delete your Personal Information. We will use commercially reasonable efforts to honor your request.
Communications. We use your Personal Information to contact you regarding our newsletters, marketing, or promotional materials or other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or update your account settings. We may use your Personal Information to respond to your questions and/or inquiries.
To personalize or improve the user experience. We may aggregate your Personal Information with other information collected from other users to attempt to provide you with a better experience, to improve the quality and value of the Services, and to analyze and understand how our Services are used. We also use Automatically Collected Information internally to increase our functionality and user-friendliness, and to better tailor our Services to our users' needs.
Fraud detection and prevention. We may use your Personal Information to detect and prevent potential fraud with respect to the Services. For example, we use your mobile phone number to provide you with a one-time verification code to ensure you are not a robot.
3. INFORMATION WE DISCLOSE TO THIRD PARTIES
We will only share your Personal Information at your direction, with your consent, or in the following circumstances:

Other Users. When you register through the Services and submit Personal Information to create a profile, other users will be able to view your username and channel name (if applicable). If you do not want Personal Information to be viewed by others, we recommend that you do not include Personal Information in your username or channel name. Should you choose to provide additional Personal Information (e.g., photos, location data, or biographical information, etc.) as part of your username or channel name, this information may be visible to other users. Sharing additional Personal Information is voluntary and we recommend that you exercise caution in disclosing any information you consider sensitive or confidential.
Affiliates. We may share your Personal Information with companies under common ownership and control of caly-film, including the parent company and its affiliates.
Third Party Service Providers. We may retain third party service providers to provide services on our behalf (e.g., maintenance services, web analytics and improvement of the Service's features) or to assist us in analyzing how our Services are used, including with certain third parties for industry analysis, demographic profiling, and other purposes. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may disclose Automatically Collected Information obtained from your use of the Services to third party service providers who provide services to us.
Social Networking Sites. When you registered your account with caly-film, you expressly agreed with and consented to this Privacy Policy. With your consent to this Privacy Policy, along with any consent you have given with respect to any Social Networking Sites (“SNS”), video titles, descriptions, and/or thumbnails that you engage with, together with Personal Information that may identify you (e.g., IP address, device ID, or other identifiers) may be shared with an SNS. With your consent to this Privacy Policy, we may also share information regarding the videos that you view through the Services (e.g., video titles, descriptions) along with other information, to assist us and other third parties to provide you with more personalized content, including ads displayed on caly-film as well as other platforms. Your SNS consent preferences may be changed at any time through your SNS account. Please be advised that where your SNS account preferences do not grant consent to share information regarding the videos you view through the caly-film Services, we may still share other Personal Information about you for any other purpose described in this Privacy Policy.
Legal Obligations. We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to satisfy our legal obligations. This may include: (i) to comply with the law or in response to a subpoena, court order, government request, or other legal processor to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (ii) to protect the interests, rights, safety, or property of us, or any of our users, subsidiaries, affiliates, employees, or others; (iii) to monitor compliance with and enforce our Website Terms and Conditions of Use; (iv) to operate the systems that ensures the Services function properly; or (v) if we believe in good faith that a disclosure is necessary. When permitted by law, we will attempt to notify you before we disclose your Personal Information to satisfy our legal obligations.
Business Transactions. In the event that caly-film goes through a business transition, such as a corporate divestiture, merger, acquisition, joint venture, bankruptcy, dissolution, reorganization, or any other similar transaction or proceeding, your Personal Information may be sold, divested, assigned, shared, or otherwise transferred in connection with the proposed transaction. You may opt-out of the transfer of your Personal Information to the successor entity, if that entity has not committed to comply with this Privacy Policy or a privacy policy that is in all material respects as protective of your Personal Information as this Privacy Policy.
We may use and disclose certain aggregated or de-identified information to our affiliates, business partners, and service providers, or through certain aggregated analytics data available through our Services to other users. Such aggregated and/or de-identified information cannot reasonably be used to identify you.

4. CHOICES REGARDING YOUR INFORMATION
Email Communications. If you decide at any time that you no longer wish to receive email communications from us, please follow the unsubscribe instructions provided in any of the communications or update your account settings.
Social Networking Sites. When you log-in through an SNS account, such as Facebook, the privacy policy of that SNS applies to their collection, use, and disclosure of your Personal Information. In addition, the SNS may collect Personal Information about your activity on the caly-film website for the purpose of providing you with targeted advertising and other services. You may determine whether or not your activity on the Services will be shared and disclosed through the privacy settings on your SNS accounts. Please review the privacy policies of the SNS with whom you engage to better understand the information they collect and the choices you have with respect to the collection, use, and disclosure of your Personal Information. You can disable the feature that links your account to a SNS at any time by logging into your SNS account and selecting the option to disable connection to your SNS.
5. LINKS TO OTHER WEBSITES
Our Services contain links to other third-party websites and online services. If you choose to visit another website or online service by clicking on a link, you will be directed to that third party's website or online service. Other websites and online services follow different rules regarding the collection, use and/or disclosure of Personal Information. We encourage you to read the privacy policies or statements of the other websites or online services you visit before providing any information or using such websites or services to carefully understand their privacy practices.

6. DATA SECURITY
We care about the security of your Personal Information. caly-film maintains administrative, technical, and physical safeguards reasonably designed to guard Personal Information that has been provided to us from loss, misuse or unauthorized access, disclosure, alteration, or destruction. We utilize commercially reasonable safeguards to preserve the integrity and security of information collected and maintained through the Service and comply with applicable laws and industry standards to secure and protect information transmitted via or stored through our Services. However, while we strive to protect your information, we cannot guarantee the security of information you transmit to our Site.

7. COOKIES AND OTHER TRACKING TECHNOLOGIES
“Cookies” are small amounts of data generated by a website and saved by your web browser. Browsers store the data temporarily and return it to the server on subsequent visits or requests. Web beacons are a small image file (usually a transparent 1x1 pixel image) used for tracking purposes. They may be placed in a webpage or HTML email to record when the content was loaded. We use the information collected by web beacons to statistically monitor how many people are using our Services. We utilize both cookies, pixels, and web beacons to help us keep our Services secure, measure the performance of our Services, understand how visitors interact with them, count numbers of visitors, and improve the user experience. For example, cookies, pixels, and web beacons may be embedded in videos or web pages to collect certain types of information from your device or web browser in order to determine if you have viewed a particular video, web page, or advertisement.

In addition to caly-film's use of cookies and web beacons, we have relationships with advertising companies and SNS, including caly-film's own Ad Manager, who may serve ads and/or collect certain information when you visit our web site. These advertising companies typically use a cookie, pixel, or third-party web beacon to collect this information. For example, these companies may use information collected about you (e.g., IP address, click stream information, browser type, time and date, subject of advertisements clicked or scrolled over) during your visits in order to provide advertisements about goods and services that may be of interest to you. In addition, these advertising companies and SNS may use their own unique identifiers to identify you, and this information may be collected from you by these third parties, consistent with their own privacy policies.

Most browsers are set to accept cookies by default, but you can control and manage the use of cookies on your browser or device by deleting them from your browser history when you leave our website. If you do not wish to receive cookies, you may set your browser to reject cookies or alert you when a cookie is set on your computer. If you use a mobile device to access our Services, certain information associated with your device may be collected (e.g., browser type, device manufacturer, device model, etc.) and used for purposes similar to cookies. Most mobile devices allow you to disable the ability for geolocation information to be collected from your mobile device. The help function on most browsers and mobile devices contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or disable the collection of geolocation data. Please be advised, if you disable certain cookies, some of the features of our website may not function properly or be available to you, such as those which require identification.

Do Not Track Requests. Some web browsers have Do Not Track (“DNT”) or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. Currently, caly-film does not respond to DNT signals and will continue to collect information about you even if your browser's DNT functionality is activated. By selecting the DNT option on your browser, this may not affect our collection of information related to cookie or other tracking technologies.

8. NOTICE TO CALIFORNIA RESIDENTS
The California Consumer Privacy Act (“CCPA”) provides California residents with right to receive certain disclosures regarding the collection, use, and sharing of their Personal Information, and the right to know, access, delete, and limit sharing of Personal Information. In the past twelve months, we may have collected the categories of Personal Information as described in the “Information We Collect” section. We provide California residents the privacy rights listed below in accordance with the CCPA:

The right to know. You may request the following information about how we have collected and used your Personal Information during the past 12 months: (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we have sold or disclosed for a business purpose.
Within the preceding 12 months, caly-film has collected the following categories of Personal Information to provide our Services: Identifiers (e.g., email address, username or password, IP address); Categories of Personal Information under the California Customer Records statute (e.g., name, postal address, phone number, payment information); Internet Activity (e.g., browsing history or interaction with the Services); and Inference Data (e.g., personal profiles reflecting preferences)
We obtain Personal Information from the following sources: (i) directly from you (e.g., when you communicate with us or through account registration); (ii) indirectly from you (e.g., when you visit our websites)
Within the preceding 12 months, caly-film has used the following categories of Personal Information: Identifiers; Categories of Personal Information under the California Customer Records statute; Internet Activity; and Inference Data for the following business purposes: operate and improve our business; to fulfill the purpose for which the Personal Information was collected (e.g., to provide Services); to maintain or improve the quality of our Services; detecting and investigating fraud and other illegal activities.
Within the preceding 12 months, caly-film has disclosed the following categories of Personal Information for a business or commercial purpose: Identifiers; Categories of Personal Information under the California Customer Records statute; Internet Activity; and Inference Data. We disclose your Personal Information, for a business purpose, to service providers, our partners or affiliates, or third parties with whom we collaborate.
The right to deletion. In certain circumstances, you have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
The right to equal service. If you choose to exercise any of these rights, caly-film will not discriminate against you. However, if you exercise certain rights under this Privacy Policy, please be advised that you may be unable to use or access certain features of caly-film's Services.
You may exercise your right to know and your right to deletion two times a year free of charge. To exercise your right to know or your right to deletion, contact us through one of the methods listed at the bottom of this Privacy Policy.

Request Verification and Response. We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you are a registered user of our Services, we will use our existing account authentication practices to verify your request. If you do not have an account with us, we may request additional information about you. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose. We will confirm our receipt of a verifiable consumer request within ten (10) business days and respond to a verifiable consumer request within forty-five (45) days of receipt. If we need more time to respond, we will provide written notification to you, including our reason for the need for an extension and respond to your request no later than ninety (90) days after receipt. If we cannot comply with a request, we will explain the reason in our communication to you.

Authorized Agent. You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent's request, we may verify both your and your agent's identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

Sale of Personal Information. caly-film does not sell Personal Information, as such term is defined under the CCPA. However, we may share Personal Information with third parties as directed or consented to by you. If we decide to sell your Personal Information, you will have the right to opt-out prior to any such sale.

Other California Privacy Rights. Under California's “Shine the Light” law (Ca.Civ.Code Section 1798.83), California residents are entitled to request and obtain from caly-film once per calendar year information about when we share your Personal Information with third parties for those third parties' own direct marketing purposes. To request this information, please email us at the address indicated below in the Contact Us section and note “California Shine the Light” in the subject line.

9. NOTICE TO RESIDENTS OF THE EUROPEAN ECONOMIC AREA (“EEA”) AND THE UNITED KINGDOM (“UK”)
caly-film may collect, process and retain the data of residents of the EEA or the UK in order to provide Services to its customers. If we do collect personal information from data subjects in the EEA or the UK, we are required to comply with the GDPR, UK GDPR, and applicable local laws with regard to certain Personal Information we collect. We process Personal Information for the purposes described above. If we use or process Personal Information in ways other than described in this Privacy Policy, we will provide you with specific notice at the time of collection.

For such Personal Information, caly-film is the data controller of the Personal Information.

Any Personal Information we may collect is detailed in “Information We Collect.” We rely on the following legal bases to process your Personal Information (i) valid consent provided by you; (ii) as necessary for the performance of a contract; (iii) compliance with a legal or regulatory obligation; and (iv) to fulfill our legitimate interests unless your fundamental rights and freedoms override those interests.

How We Use Your Personal Information Lawful Basis for Processing Your Personal Information
Onboard you as a user, verify your identity, process and fulfill your account registration, and perform other activities that are part of our Services Our processing may be based on your valid consent or our legitimate interests to provide you with information you need and to respond to your requests.
Communicate with you by promoting our Services, including other marketing communications and newsletters Our processing may be based on your valid consent or our legitimate interest to provide you with information you need and to respond to your requests.
Improve the quality of our Services, and for other related internal business purposes Our processing may be based our legitimate interest to improve our Services.
Ensure the security and integrity of the Personal Information we process and to prevent and address fraud or breach of our Website Terms and Conditions of Use Our processing is based on our legal obligations and our legitimate interest to improve security and reduce the occurrence of fraudulent transactions.
Comply with our legal and regulatory obligations, including establishing, exercising and/or defending legal claims Our processing is based on complying with applicable legal or regulatory requirements.
Data Subject Rights. If you are a resident of the EEA or the UK, you have rights with respect to your Personal Information under the GDPR or UK GDPR. Subject to certain conditions, if you are a resident of the EEA or UK and have submitted Personal Information to us, you have the followings rights with regard to your Personal Information that we hold:

Access: You have the right to access certain information about how we process your Personal Information, including the categories of Personal Information that we process, our purposes for processing, and with whom we have shared your Personal Information;
Correction: You have the right to rectify inaccurate Personal Information concerning you and, in certain circumstances, the right to have incomplete Personal Information completed;
Deletion: You have the right to erasure of your Personal Information in certain circumstances, including when the Personal Information is no longer necessary for the purposes for which we collected it;
Portability: Where processing is based on your consent or on a contract, the right to data portability (the right to obtain a copy of the data concerning you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance from us);
Restrict Processing: You have the right to restrict our processing of your Personal Information in certain circumstances, including when the processing is unlawful or you contest the accuracy of your Personal Information;
Object to Processing: You have the right to object to our processing (including our automated processing) of your Personal Information based on our legitimate interests, in certain circumstances.
Complaints: You have the right to lodge a complaint with your local competent supervisory authority.
You can submit these requests by email or by post. Addresses are provided below. We may request specific information from you to help us confirm your identity prior to processing your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services we offer.

Special Categories of Personal Information. caly-film does not knowingly collect Special Categories of Person Information, which includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life, and sexual orientation. If you choose to provide this information through the Services, you consent to our collection of this information.

Withdrawal of Consent. Where you have given us valid consent to collect, use, and process your Personal Information in certain ways, we will rely on your consent. In instances in which we have based our processing of your Personal Information on your consent, you have the right to withdraw your consent. Please note that when you withdraw consent, we might not be able to provide you with Services. To withdraw such consent, please contact us through the methods listed below. Please note that in certain situations, we may continue to process your Personal Information after you have withdrawn consent and requested that we delete your Personal Information, if we have a legal basis to do so. For example, we may retain certain information if we need to do so to comply with a legal obligation or if it is necessary to do so to pursue our legitimate interest in keeping the Services safe and secure.

10. NOTICE TO RESIDENTS OF BRAZIL
If you are a resident of Brazil, you have certain protections and rights under the Brazilian General Data Protection Law (“LGPD”). We rely on the following legal bases to process your Personal Information: (i) valid consent provided by you; (ii) as necessary to fulfill a contract; (iii) to fulfill our legitimate interest, unless your fundamental rights and liberties outweigh those interests; or (iv) to comply with a regulatory or legal obligations.

If you are a resident of Brazil, you have the right to obtain the following regarding your Personal Information: (i) confirmation of processing; (ii) access to data upon request; (iii) correction of inaccurate data; (iv) deletion of unnecessary or excessive data; (v) transfer of data; (vi) which entities with whom data has been shared; and (vii) block the processing of data.

Sensitive Data. As defined under LGPD, caly-film does not knowingly collect Sensitive Data, which may include information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life, and sexual orientation. If you choose to provide this information through the Services, you consent to our collection of this information.

For website visitors and users of our Services who are located in Brazil, the data controller processing your Personal Information is caly-film.

11. NOTICE TO RESIDENTS OF USA
If you are a resident of USA, you have rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”). We strive to ensure the information we have about you is accurate and will your personal information for as long as required to comply with all business, legal and regulatory record keeping requirements and aligned with our internal policies and retention schedules. You have the right to access, correct, complete or delete any Personal Information that we process about you in our role as a data controller for the processing of such Personal Information.

We will seek your consent, either express or implied, prior to the collection, use, or disclosure of your Personal Information. If you object to the processing of your Personal Information, or if you have provided your consent to processing and you later choose to withdraw it, you have the right to withdraw your consent to the processing of your Personal Information under certain circumstances. We will do our utmost to ensure the information we have about you is accurate and complete and will keep your Personal Information for as long as required to comply with all business, legal and regulatory record keeping requirements and aligned with any internal policies and retention schedules.

If you wish to exercise any right set forth in this section, please contact us through one of the methods listed at the bottom of this Privacy Policy. We may request specific information from you to confirm your identity prior to processing your request.

12. INTERNATIONAL DATA TRANSFERS
Our Services are based, controlled, operated, and administered by us in the United States and USA, where caly-film's servers are located. Please be advised that the laws of the United States and/or USA may not provide the same level of data protection as the jurisdiction in which you reside. If you visit our websites or use our Services from a jurisdiction outside of the United States or USA, your Personal Information may be transmitted to, stored, or processed in the United States and/or USA and by using our websites, you authorize the transfer to and processing of your Personal Information in the United States and/or USA. If we transfer your Personal Information internationally in a manner which requires certain legal protections for your Personal Information, we will do so in accordance with appropriate safeguards mandated by applicable data protection laws. This may include, but is not limited to, transferring Personal Information pursuant to agreements that incorporate standard contractual clauses approved by applicable data protection authorities, or by other means approved by data protection authorities in the applicable countries from which the Personal Information is transferred.

13. DATA RETENTION
We may retain your Personal Information for as long as reasonably necessary for the purposes for which it was originally collected, and the purposes outlined in this Privacy Policy. In some circumstances, we may store personal information for longer periods of time as necessary to comply with legal or regulatory requirements.

14. CHILDREN'S PRIVACY
We do not knowingly collect Personal Information from children under 13 and children under the age of 13 are not permitted to use our Services. If we become aware that a child under 13 has provided us with Personal Information, we will promptly delete such information from our systems. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, the parent of guardian should contact us via one of the contact methods listed below.

15. CONTACT INFORMATION
If you have any questions or would like to exercise your rights regarding this Privacy Policy, please contact us at the addresses listed below. Please include “Privacy” in the subject line of your inquiry so that we may route your communication to the appropriate party. Additionally, if you have complaints about caly-film's processing of your Personal Information, you may have the right to lodge a complaint with the applicable supervisory authority in the jurisdiction where you reside.

By email:
[email protected]