Last Modified: August 17, 2023
Aylo Freesites Ltd (hereinafter "we", "us" or "our") operates the website tube8.com (hereinafter "Tube8" or the "Website") and is the controller of the information collected or provided via the Website.
If you have any questions about our privacy practices, please see "Contact Information" below for information on how to contact us.
- on the Website and your email communications with the Website,
- through our mobile applications that provide dedicated non-browser-based interaction between you and the Website, or
The Data We Process About You
We may process different kinds of personal data about you, depending on whether you chose to create an account with us.
Persons who visit the Website without logging in or registering ("Unregistered Users"):
- Contact Information: We process email address or any other information which you voluntarily provide to us at your direction for a specific function, for example a contest or survey. In some cases, we process usernames or similar identifiers, and email addresses as part of the process to verify that you are over the age of majority required to have access to the Website and to view their contents.
- Website activity data: We process information about how you use our Website, products and services and interact with our content and advertisements, including the pages you visit in our Website, search history, and the referring web page from which you arrived at our Website. We process browser and operating system information, devices you use to access the Website and your time zone setting. We also process online identifiers. Specifically, we process internet protocol (IP) address information, and we set cookies as explained below in the section on Cookies and Automatic Data Processing Technologies.
- Identifiers: Some users may be asked to provide identifiers (including government-issued photo identification as well as other documentation) in order to verify that they are over the age of majority required to have access to the Website and to view their contents. In such cases, this information is processed by trusted third party age verification service providers. This policy does not apply to the privacy practices of these third-party age verification service providers. Read the privacy terms and conditions of these service providers carefully.
Persons who choose to create an account on the Website (hereinafter "Registered Users"):
We collect from Registered Users the same categories of information described above for Unregistered Users:
- Contact Information: We collect username or similar identifier, and email address.
- User Submitted Personal Information: We collect information you submit in order to personalize your account or for a specific function, for example date of birth, age, gender, your interests, preferences, feedback, survey responses, your preferences in receiving marketing from us and our third parties, and your communication preferences, as well as any other information which you voluntarily provide to us at your direction for a specific function.
We may process your data to produce and share aggregated insights that do not directly or indirectly identify you and are not associated with you. Such aggregate information is not personal information.
The Sources from Which We Process Personal Information
We process personal information in the following ways:
- Directly from you: We process the categories of information listed above directly from you.
- Automated technologies or interactions: As explained in the section below on Cookies and Automatic Data Processing Technologies, we set cookies and other automatic techniques to process website activity data when you visit the Website or other websites owned by our corporate group.
Purposes for Which We Process Your Personal Information
We process personal information for the purposes described below.
- Provision of services: We process identifiers, website activity data, and, additionally, for Registered Users only, contact information, and, where applicable, payment and commercial information and user contributions to present our Website and its contents to you, including any interactive features on our Website, to provide you with information, products, or services that you request from us, and to verify your eligibility and deliver prizes in connection with contests and sweepstakes.
- Customer management (Registered Users Only): We process identifiers and contact information, and payment and commercial information to manage a Registered Users’ account, to provide customer support and notices to the registered user about their account or subscription, including expiration and renewal notices, and notices about changes to our Website or any products or services we offer or provide through them.
- Customization of content and marketing (Unregistered Users and Registered Users): We process for both Registered Users and Unregistered Users, identifiers and contact information, website activity data; and for Registered Users, user submitted personal information and user contributions to analyze your use of, or interest in, our Website’s content, products, or services, in order to develop and display content and advertising tailored to your interests on our Website.
- Analytics: We process identifiers and website activity data to determine whether users of our Website are unique, or whether the same user is using the Website on multiple occasions, and to monitor aggregate metrics such as total number of visitors, pages viewed, demographic patterns.
- Functionality and security: We may process any of the categories of data we process to diagnose or fix technology problems, to verify your payment information, and to detect, prevent, and respond to actual or potential fraud, illegal activities, or intellectual property infringement.
- Compliance: We may process any of the categories of data we process to enforce our terms and conditions and to comply with our legal obligations. In certain jurisdictions, this includes our legal obligation to verify the age of users having access to our Website.
Our Legal Bases Under Canadian and European Union (EU) Privacy Law
We have the following legal bases under Canadian and EU privacy law for processing your personal data for the purposes described under Purposes for Purposes for Which We Process Your Personal Information section:
- We process personal data for the purposes of providing the services, customer management, certain customization of content (e.g., based on your selected preferences, favorites and ratings), and functionality and security because the processing is necessary for the performance of a contract, specifically it is necessary to provide the services or products you have requested, or to provide our Website and services in a manner consistent with our terms and conditions and any other contract that you have with us.
- We process personal data, including identifiers, for the purpose of verifying your identity because such processing is necessary for us to comply with a legal or regulatory obligation.
- We process personal data for the purposes of customization of advertising, marketing, and analytics for our legitimate interests.
- We process personal data for functionality and security because it is necessary for our legitimate interests, and in certain cases because the processing is necessary for us to comply with a legal or regulatory obligation.
- We process personal information in specific circumstances where you have provided your consent to such processing.
Disclosure of Your Personal Information
We disclose personal information:
- To the public: When you submit user contributions including audio/video content, you are using our Website and services to make that information public.
- Within our corporate group: We may disclose any of the categories of personal information to members of our corporate group (including affiliates and related entities) to the extent this is necessary for our purposes listed in the sections above.
- Service providers: We disclose the categories of personal information we process to our authorized service providers that perform certain services on our behalf. These services may include payment processing and fulfilling orders, identity and document authenticity verification including age verification, risk and fraud detection and mitigation, customer service, marketing and advertising, customization of content, analytics, security, or hosting our Website or supporting our Website’s functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to process such information for any other purposes.
- Legal successors: We may disclose all of the categories of personal information we process to a buyer or other successor in the event of a merger, acquisition or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding.
Cookies and Automatic Data Processing Technologies
We currently use the following types of cookies, which are set by the Website’s domain, or by other domains we own or control:
- Strictly necessary cookies: These are cookies that are required for the operation of our Website. These include, for example, cookies that enable a user to log in to our Website and to check if a user is allowed access to a particular service or content.
- Functionality cookies: These cookies help us to personalize and enhance your online experience on our Website. This type of cookies allows us to recognize you when you return to our Website and to remember, for example, your choice of language.
- Analytics cookies: These cookies allow us to recognize and count the number of users and to see how users use and explore our Website. These cookies help us to improve our Website, for example by ensuring that all users are able to find what they are looking for easily. Additionally, we are using third party session recording technologies that helps us better understand our users’ experience, however, the recording data is pseudonymized.
- Targeting and Advertising cookies: These cookies record visits of a user on our Website, the pages a user visits and the links a user follows in order to enable us to make our Website more relevant to the user’s interests and to help us serve ads that might be of interest to the user. Targeting and advertising cookies are only used for Unregistered Users and Registered Users.
Analytics, Functionality and Advertising / Targeting cookies can be switched off at any time by accessing the ‘Manage cookies’ option that is located at the footer of our website. However, if you decline to accept these cookies, some functionality on our Website may be disabled and can interrupt your access to certain parts of our Website.
Cookies can be either session cookies or persistent cookies. A session cookie expires automatically when you close your browser. A persistent cookie will remain until it expires, or you delete your cookies. Expiration dates are set in the cookies themselves; some may expire after a few minutes while others may expire after multiple years.
Do Not Track: Our systems do not recognize browser “Do Not Track” signals.
Use of Google Analytics: We use Google as a service provider to process information about how users use the Website, including by processing website activity data through first-party cookies set by our domains, and third-party cookies set by Google. Because we activated IP anonymization for Google Analytics, Google will anonymize the last octet of a particular IP address and will not store your full IP address. Google will process the information only for the purpose of providing Google Analytics services to us and will not process this information for other purposes. The information processed by Google Analytics may be transmitted to and stored by Google on servers in the United States pursuant to standard contractual clauses approved by the EU. You can learn more on how Google processes data here, and you can opt-out of Google Analytics by visiting the Google Analytics opt-out page or by accepting only necessary cookies.
Third-party Process of Cookies and Other Tracking Technologies
You can set your browser to refuse all third-party cookies, or to alert you when cookies are being sent.
Your Choices About How We Process and Disclose Your Personal Information
We strive to provide you with choices regarding the personal information you provide to us.
- You can choose not to provide us with certain personal information, but that may result in you being unable to use certain features of our Website, because such information may be required in order for you to register as a member, purchase products or services, participate in a contest, promotion, survey, or sweepstakes, ask a question, or initiate other transactions on our Website.
- The Cookie Banner can be utilized to customize your cookie preferences. The Cookie Banner will record when you have consented to our cookies. For logged in users, we will ask for consent once a year or when we have major changes to our cookies, to ensure you stay up to date with changes to our cookie and privacy policies. For non-logged in users, your Cookie Banner selection will be kept only for the specific session. The Cookie Banner specifically controls the Functionality, Analytics, and Advertising cookies set by using our website. Strictly necessary cookies cannot be disabled, nor can the tool be used to block cookies on third party websites linked from our website. You can access the Cookie Banner anytime by clicking on the ‘Manage cookies’ option that is located at the footer of our website.
- You can opt out of receiving marketing emails from us using the opt-out link provided in our emails or by changing your preferences in your account settings. If you are a Registered User, we may continue to send you other types of important emails e.g., e-mails about your transactions, account, or orders. You may use your account settings to delete your user contributions and audio/video information.
- You may also delete and deactivate your account with us at any time unless required not to do so by law or by a court order. If you do so, your profile will no longer be accessible by you. If you later choose to have an account with us, you will have to sign up for a new account as none of the information you previously provided or saved within your account will have been saved.
Your Rights Related to Your Personal Information
Generally, in some regions like Canada, European Economic Area (“EEA”), and the United States, you have certain rights regarding the personal information we process and that is related to you, including the right:
- to receive information on the personal information we hold about you and how such personal information is processed (“right to access”);
- to correct inaccurate personal information concerning you (“right to data rectification”);
- to delete/erase your personal information (right to deletion, “right to be forgotten”);
- to receive the personal information provided by you in a structured, commonly used, and machine-readable format and to transmit the personal information to another data controller (“right to data portability”);
- to object to the processing of your personal information where such processing is based on our legitimate interests or on public interests (“right to object”);
- in some cases, to restrict our processing of your personal information (“right to restriction of processing”); and
- to withdraw your consent at any time where our processing is based on consent (“right to withdrawal of consent”).
You may exercise your right to access and deletion using the buttons at the bottom of this page. Additionally, you may, at any time, send us an e-mail at firstname.lastname@example.org to exercise your above rights in accordance with the applicable legal requirements and limitations. If you are located in the European Economic Area or the UK, you have a right to lodge a complaint with your local data protection authority.
Please note that unless you have created an account with us, we may not have sufficient information to identify you and therefore may not be in a position to respond to your request. Additionally, in some cases in order to adequately verify your identity or your authorization to make the request, we may require you to provide additional information.
Note that some requests to delete certain personal information will require the deletion of your user account as the provision of user accounts are inextricably linked to the processing of certain personal information (e.g., your e-mail address).
California Rights and Choices
The California Consumer Privacy Act ("CCPA") provides you certain rights in relation to your personal information:
- Right to Know: You have the right to request that we disclose certain information about our processing of your personal information over the past twelve (12) months, including the specific pieces of information we processed.
- Right to Request Deletion: You have the right to request that we delete any of your personal information we processed from you and retained, subject to certain exceptions set forth in the CCPA.
- Right to Non-Discrimination for the Exercise of Your Rights: We will not discriminate against you because you have exercised any of your rights under the CCPA.
To exercise the rights described above, please use the buttons at the bottom of this page or email us at email@example.com with the email subject line “CCPA Request”. In either case you will need to provide the following information to verify your identity and enable us to locate your information in our systems: your username and email address that you used to create an account with us, as well as any other information which we may reasonably request in order for us to verify your identity. We may require you verify that you have access to your account and/or email account that you used to register with us.
You can designate an agent to make a request by executing a notarized power of attorney to have that person act on your behalf and providing that person with the information listed above that allows us to verify your identity and locate your information. Alternatively, you will need to directly confirm your identity with us using the methods described above, sign an authorization for the agent to act on your behalf and provide us with confirmation that you have done so.
We disclose certain categories of California residents’ personal information for our business purposes, as described in the section above titled Disclosure of Your Personal Information.
Resident’s Rights – Jurisdictions in the United States, Where Applicable
We do not sell, trade, or exchange the Registered Users’ personal information with anyone for money.
Notice to Law Enforcement
The following information serves as a guideline for law enforcement officials seeking disclosure of records. You may serve us a valid court order, subpoena, search warrant or equivalent legal or official administrative document by respecting the following conditions:
- The document(s) is uploaded, and all required fields have been filed out adequately on our platform for Legal Service Process located at: https://legalservice.aylo.com/legal/datarequest
- The document(s) you are serving is correctly issued by a valid Court of Law or equivalent legal or administrative authority to us (See Website’s footer to find our operating entity);
- The document(s) is also sent by mail at the following address: 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540.
We reserve the right to refuse online service through our Website, namely in cases where the above requirements are not met and require formal legal service at the above address. In such event, you will be notified. We may raise or waive any legal objection or right available, in our sole discretion.
Transfers of Your Personal Information to Other Countries
Where the laws of your country allow you to do so, by using the Website you consent to the transfer of information that we process about you, including personal information, to other countries in which we, members of our corporate group (including affiliates and related entities) or our service providers are located. When we transfer personal information to countries outside of the European Economic Area ("EEA") or other regions with comprehensive data protection laws, we will ensure that the information is transferred in accordance with the applicable laws. Where relevant, our transfers outside the EEA are made pursuant to standard contractual clauses approved for use by the European Union.
Retention of Personal Information
We will only retain your personal information for as long as your account is active, or for as long as necessary to fulfil the purposes we processed it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider a number of factors, including what personal data we are processing, the risk of harm from any unauthorized disclosure, why we are processing your personal data and whether we can achieve this outcome by another means without having to process it.
Where permissible, we will also delete your personal information upon your request as explained above in the section Your Rights Related to Your Personal Information.
Third-Party Links and Sites
You may also contact us at 195-197 Old Nicosia-Limassol Road, Block 1 Dali Industrial Zone, Cyprus 2540, Phone: +357 22662 320, Fax: +357 22343 282.
Our Data Protection Officer can be contacted at the following email address: firstname.lastname@example.org.
Manage My Data
With respect to applicable and relevant data protection laws in users' jurisdictions, Tube8 Registered users may request for a copy of their personal data, as well as request Tube8 to delete their personal data.
Note: AdBlocker add-ons interfere with the Manage My Data system. Please disable them.