Privacy Policy


PRIMECUTT PRIVACY POLICY


PrimeCutt respects your privacy and has developed this privacy policy (the “Privacy Policy”) to present our commitment to protecting your privacy and to explain how we collect, use, and share Personal Data from or about you in connection with your use of the PrimeCutt Service (the “Data”).


We encourage you to read this Privacy Policy carefully when using the PrimeCutt Service or transacting business with us.


Any reference to “PrimeCutt”, “we”, “us”, or “our” in this Privacy Policy will always refer to “PrimeCutt.Com


DEFINITIONS

The terms “PrimeCutt Service” or “Service” refer to the following: the PrimeCutt principal website accessible at www.primcutt.com and at any of its local versions (the “PrimeCutt Site”), the PrimeCutt secondary websites (“Secondary Sites”), the PrimeCutt video player when it is embedded onto any website (the "Video Player"), the PrimeCutt apps and web-apps (the “PrimeCutt Applications”) as accessible via any current or future device capable of distributing the PrimeCutt Site and/or the Video Player, together with any PrimeCutt products, content, channels, software, data feeds, services and functionality.


In connection with its main activity as a content hosting platform, PrimeCutt operates Secondary Sites addressed to professionals in the advertising industry, such as software developers wanting to contribute to or use the PrimeCutt APIs, content right holders interested in the PrimeCutt’s Partner Program, advertisers, media agencies and various actors of the marketing sector who wish to learn more about our offering. All of the Secondary Sites can be accessed from the PrimeCutt Site but, due to the particularity of their audience, may be subject to distinct terms of use. The use of their visitors’ Data is limited by the particular purpose of these sites and is further explained in the dedicated Section 9 of the present Privacy Policy.


The term “Commercial Partner” refers to entities PrimeCutt may cooperate with while carrying out its Services. In particular, Commercial Partners may include content editors, advertisers, media agencies and other actors of the on-line marketing sector.


The term “Content” refers to videos available on the Service.


The terms “Personal Data,” “Data Controller,” “Joint Controller,” “Data Processor” and “Processing” used in the present Privacy Policy shall have the same meaning as defined in the General Data Protection Regulation (“GDPR”), or unless, otherwise stated herein, under applicable local data protection laws. Personal Data processed by PrimeCutt is referred to as “Data”.


We encourage you to read this Privacy Policy carefully when using the PrimeCutt Service or transacting business with us.




  1. GENERAL INFORMATION



    • 1.1. PrimeCutt’s Role in Processing of Personal Data

      Certain Data from or about you may be collected or otherwise processed when you use the PrimeCutt Service, regardless of whether you do so as a Viewer, Visitor, User, or member of the “Partner Program” (as defined in the PrimeCutt Terms of Use).


      If you reside in a country that is part of the European Economic Area, the GDPR is applicable to the collection of your Personal Data. If you reside outside of the EEA, local laws are applicable to such collection.


      Note that the laws applicable to further processing of your Personal Data depend on your country of residency and that of an entity that uses your Personal Data.


      When PrimeCutt (or its Data Processors) process your Data, we do so for the purposes that we have defined and explained to you in the present Privacy Policy and, if applicable laws require so, subject to existence of a valid legal basis justifying such Processing (e.g. your consent, legitimate interest, contract execution, legal obligation). In such cases, PrimeCutt acts in its role of a Data Controller. We may hire some service providers to help us implement certain aspects of your Data Processing. In doing so, these service providers act on our behalf following our instructions and thus are considered our Data Processors.


      In some cases, PrimeCutt and its Commercial Partners may process your Personal Data together for joint purposes. Under these circumstances, PrimeCutt and these Commercial Partners act in their role of Joint Controllers.



    • 1.2. Legal Basis for Processing of Personal Data

      The GDPR provides several situations upon which PrimeCutt can rely for Processing of Personal Data, namely consent, contractual necessity, compliance with a legal obligation, vital interests of data subjects, public interest or legitimate interest.


      When Processing of your Personal Data requires your consent, we ask you to communicate your consent prior to such Processing. We will ask you to express your consent by, for example, clicking on the “Accept All” button within our cookie banner available on our Site, our Secondary Sites or in our Video Player, or by expressing your consent by a clearly identified positive action such as clicking an ad or a content or by using our search engine on our Service. You might also be asked to activate a toggle on a form your Data is being collected on. , or When your consent is collected for several purposes you may decide independently for each of the purposes your consent is being collected. For consent collected through a cookie banner you may personalize you consent decision from within our Consent Management Platform, accessible from the cookie banner, the footer of our website homepage or from the settings of our Applications or Video Player.


      You can always choose not to consent to Processing of some of your Data, withdraw your consent, or oppose such Processing (unless the applicable laws authorize or require us not to take into account such decision) as further explained herein. However, this may limit your ability to take full advantage of the many features we offer, including features that are needed for our Service to operate as it is intended to and, consequently, seriously deteriorate your user experience. If you do not agree to the collection and use of Data needed for our Service to operate at its optimal capacities, we strongly advise you not to use PrimeCutt Service as we will not be capable of providing you with the high quality service you may expect from us.



    • 1.3. Transfer of Data

      The Data collected by us through our Service may be sent to and stored on servers located in the United States, Germany, and other countries around the world.


      We ensure that legally required, appropriate contractual or other mechanisms are present prior to transfers of Data outside of the EEA.






  2. 2. DATA WE COLLECT


    We may collect Personal Data that can identify you directly, such as your name and email address, and other information that does not identify you directly. This Section explains what Personal Data we collect and how we collect such information.



    • 2.1. Categories of Data We Collect

      • 2.1.1 Data You Provide to Us

        We collect Personal Data you provide to us when you interact with the PrimeCutt Service, including when you sign up for an account, upload Content, create a playlist or share a playlist with others. For instance, when you register to use the PrimeCutt Service, we may collect your name, email address, birth date, gender, and other similar information. If you are a member of the PrimeCutt Partner Program, PrimeCutt may also collect your payment information, such as your address, bank account details and authentication information, as well as billing, shipping and contact details. If you are a user of our loyalty reward program, we may collect your credit card details. In addition, PrimeCutt may collect information you provide to us when you respond to surveys, set your preferences on the PrimeCutt Service, directly contact PrimeCutt through the PrimeCutt Help Center or by other means, or agree to participate in promotions that PrimeCutt may offer from time to time. PrimeCutt also allows multiple profiles to be set up under one account, so we may collect information you provide to us if you create such profiles.



      • 2.1.2 Usage and Log Data

        We collect information when you use the PrimeCutt Service or view PrimeCutt ads outside of the PrimeCutt Service. We may also collect information from or about the computers, phones, tablets, or other devices where you install PrimeCutt Applications or otherwise access the PrimeCutt Service, depending on the permissions you have granted. Examples of this information may include your IP address, device ID number, settings of the browser and software you use (such as type and version of an operating system or its language settings), activity on the PrimeCutt Service including information about the videos you watch on the Service (e.g. video titles and categories), about the ads you are being shown and your interaction with them, the frequency and duration of your activities, page views, referral URLs, network state, and carrier information.



      • 2.1.3 Account and Profile Data from Third-Party Services

        If you choose to log-in, access or otherwise connect to the PrimeCutt Service or contact PrimeCutt through a third-party service (e.g. Facebook), such method being completely optional and subject to your exclusive decision, we may, in order to execute your choice of a log-in or contact method, collect your user ID and user name associated with that third-party service as well as any other information you make public using that service. We may also collect information you have authorized the third-party service to share with us (such as, for example, your user ID, billing information, public profile information, email address, birthday, and profile data).



      • 2.1.4 2.1.4. Third-Party Data

        We may, if you authorized such third parties to share such information with us or if we believe that such sharing is in conformity with the applicable laws, receive from them or share with them information about you originating from other sources, such as data aggregators, public databases, and our Commercial Partners, be it affiliated or unaffiliated entities. Shared data (whether identified, pseudonymized or anonymous and whether collected online or offline) may include information about your interests, demographic data, purchasing behavior, and your online activities (such as websites you have visited and/or advertisements you have viewed).


        We may combine the shared information with the information we collect from or about you and use it in the manner described in Section 3 of the Privacy Policy or as otherwise permitted by law.





    • 2.2. How the Data Is Collected

      Like many online services, we use, directly or via our subcontractors, various technologies to collect usage data and store your user settings. The Data thus collected helps us propose, protect and improve the PrimeCutt Service and to personalize your user experience by adapting the Content and advertising to your taste.


      Despite a variety of the actual measures deployed, the various technologies used to collect data are commonly referred to as “cookies” and their use is regulated by “cookie laws.” Whenever the applicable laws subject the use of cookies to user consent, PrimeCutt asks for your consent prior to their use.


      A “cookie” is a small data file that is transferred to your computer’s hard disk. A cookie life is limited to its purpose and does not, in general, exceed 13 months. A cookie expires upon the end of its validity period. A cookie may be deleted before the end of its validity period if you or the technologies you use (e.g. your operating system) do so. The different categories of cookies and assimilated technologies we use are further described below.



      • - Cookies and Local Storage

        We may use both session cookies and persistent cookies to offer you a high quality Service, better understand how you interact with the PrimeCutt Service or with marketing material advertising the PrimeCutt Service outside of our Service; to monitor aggregate usage by our users and web traffic routing on the PrimeCutt Service; to customize Content and advertising; to respect the rights of the Content rights holders or that of advertisers and to be in conformity with obligations imposed by applicable laws. We may create a unique device or user ID (“Service ID”) for you and store it in a cookie so we can customize your experience based on your preferences. These uses allow us to create a better experience for you on the PrimeCutt Service.


        We may collect information through other kinds of local storage (also referred to as "Flash cookies") and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player. These technologies are sometimes referred to as "browser cookies" even though they may be stored in different parts of your computer.


        Most Internet browsers automatically accept cookies. By changing your browser settings, you can instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. For further information on disabling cookies or deleting information contained in cookies in general, please click here. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the PrimeCutt Service, including the Video Player. For example, we may not be able to store your preferences (such as the language to be used by the Service) or login information (such as keeping your connection session active thus allowing you to be automatically recognized by the Services when you repeatedly access PrimeCutt Service on the same device) or customize the Content and advertising to your online viewing habits.



      • - Web Beacons, Pixels and other Trackers

        In addition to cookies, we may use other similar technologies such as web beacons or pixel tags, which can be embedded in web pages, videos, or emails. These technologies are mainly used to learn whether you have viewed a particular web page, ad, or email message; and determine other usage details including the time and date on which you viewed Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.



      • - Mobile Device Identifiers and Software Development Kits ("SDKs")

        We may use or work with third parties, including our Commercial Partners and service providers, who use mobile SDKs to collect information such as advertising identifiers (e.g., "ad-ID" or "IDFA") and information related to how mobile devices interact with the PrimeCutt Service. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented (a mobile SDK is a mobile app version of a pixel tag or beacon, described above). For instance, we may use this technology to analyze how you interact with Content and advertisements and to enable analytics or other features through mobile devices.


        The uses of these various technologies, notably in connection with advertising on the PrimeCutt Service, are further explained in Section 3 below.








  3. PURPOSES FOR DATA PROCESSING



    • 3.1. Purposes for which Data is Processed by PrimeCutt


      • 3.1.1. General

        We receive or collect Data, either directly or via our service providers, because we are passionate about creating an engaging and relevant experience for our users, and in order to ensure that the rights of Content right holders and advertisers are respected. We may also share some of your data with other Commercial Partners to better understand what you may be interested in.


        We use all of the legitimately collected or received information to help us provide and support the PrimeCutt Service with a first-class user experience that is adapted to each user’s tastes, as varied as they may be. The way we actually use the Data about you depends on how you use the PrimeCutt Service.



      • 3.1.2. Purposes for which Data is Processed

        PrimeCutt may process the Data for the following purposes :




        • - Provide, Improve and Develop the PrimeCutt Service. We are able to deliver the Service, personalize the Content and advertisements, evaluate the quality of our platform and the Content and make customized recommendations for you by using Data collected on our Service. We analyze that Data to understand how you use and interact with the PrimeCutt Service and discover the things you’re interested in on and off our Service and ultimately provide you with the best user experience we can offer. For example, we collect your authentication data to allow you to connect to your account, and we collect information on your language setting preferences to provide you with the PrimeCutt Service in the language of your choice. We may conduct surveys and research, test features in development and analyze the information that we have in order to evaluate and improve our existing products and services, develop new offerings or features and conduct maintenance and troubleshooting activities.




        • Communicate with You. We may use your Data to send you marketing communications, communicate with you about the PrimeCutt Service and update you about our policies and terms. We also may use your information to respond to you when you contact us, or for any other purpose that is disclosed to you at the time we collect the Data or that is related to a request made by you or related to you. To learn about opting out of promotional communications, please see the information we have provided in Section 9 below (“Your Rights & Opting-Out”).




        • Pay You. If you are a member of the PrimeCutt Partner Program we use your billing information, such as your billing address or payment methods details, to proceed with payment of sums generated under our Partner Program monetization features. If you choose a third-party payment method, we will communicate to the payment service provider of your choice all information necessary to process due payments. Note that we do not use or otherwise access your credit card information.




        • Your Geographic Location. We may collect your device’s location data (limited to the city level only). This information not only allows us to serve you Content related to your local area, such as local news and sports videos, but enables us to ensure the respect of Content geo-restrictions imposed by the Content right holders. This Data may also be used to tailor advertising to you based on your location by, for example, not showing you ads for services unavailable at your location.




        • Ensure Safety and Security of PrimeCutt Service and its Conformity with Applicable Laws. We may use the Data to ensure the security of our Service and anti-fraud protection. Our dedicated engineering teams do so by using automated procedures and advances technologies such as data encryption and machine learning. Consequently, your Data may be processed as part of investigation of suspicious account activities or violations of our legal terms and policies. In conformity with our legal obligations, PrimeCutt maintains connections logs linked to each user’s account activities and communicates them, if requested to do so pursuant to applicable legal procedures, to duly authorized public authorities.







    • 3.2. Purposes for which Data is Processed by our Commercial Partners

      When you watch Content or ads on the PrimeCutt Service our Commercial Partners may process, either directly or via their respective subcontractors, information about you and your use of our Service. They may use this information, including in combination with other data they have access to, in order to adapt content and ads that may be shown to you on our and on third parties’ services. While doing so, our Commercial Partners process your Personal Data in their capacity as Data Controllers and follow privacy policies that are their own.


      Your Data may be disclosed to or shared with our Commercial Partners. We do so for a common purpose - in order to learn more about your tastes and offer you more personalized services, products and ads


      When disclosed Data is used by a Commercial Partner for its own purposes, it is that Commercial Partner who is a Data Controller for the Processing it undertakes.


      As a Data Controller, each Commercial Partner determines the purpose for which it wishes to process your Personal Data. These purposes may include the development, improvement and delivery of their services, audience and service analytics, personalization and adaptation to your centers of interest of their content, commercial offerings and ads, whether on or outside of the PrimeCutt Service, conformity with their respective contractual and legal obligations, such as, for example, geographic restrictions of their content exploitation rights, calculation of applicable fees or anti-fraud measures.


      When our Commercial Partners’ collection (via the use of cookies or access to you your device) or processing of your Personal Data depends on your consent, PrimeCutt does ask you for such consent on behalf of our Commercial Partners. Consequently, you may, at all times, manage your consent and indicate the purposes you choose to consent or not to consent to by exercising your choice on the commercial partners website.


      Note that refusing the use of your Personal Data for ad-targeting purposes will not block advertisements. You will still see ads, but they will be less pertinent to your interests.






  4. DATA RECIPIENTS


    We may share personally identifiable or non-personally identifiable information collected from or about you with third parties, as explained further below (“Data Recipients”). We require such Data Recipients to adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements that we may enter into with them.



    • 4.1. Social Networking and Single Sign-On Services

      When you choose to share information with social networking services or single sign-on services about your activities on the PrimeCutt Service, such as videos you watched or “liked” on PrimeCutt Service, such information about you and your activities is shared with that social network or single sign-on service.


      Sharing with Facebook or Google. If you connect to PrimeCutt through your Facebook or Google accounts you may choose to share information about your activities on the PrimeCutt Service with Facebook or Google and their users, by, for example, publishing on Facebook or Google information about the videos you watch on PrimeCutt. Furthermore, if you visit PrimeCutt while logged-in to Facebook or Google, then those entities may record your browser details and combine technical information from your web browser with other information that each of them already knows about you. Your decision to share information about your activities on the PrimeCutt Service within your Facebook or Google profile may result in PrimeCutt sending relevant information about you to Facebook or Google. Facebook or Google may then make that information visible to their respective users in accordance with applicable law, their own data and privacy policies, and your Facebook or Google privacy settings. We recommend you familiarize yourself with Facebook’s and Google’s respective data and privacy policies and available account privacy controls. We remind you that PrimeCutt is independent from these third-party companies and that any privacy settings you might have chosen on the PrimeCutt Service are not applicable on Facebook, Google or any other social network account.



    • 4.2. Commercial Partners

      We work with a number of Commercial Partners who help us offer and improve the PrimeCutt Service. Such Commercial Partners include, for example, our Content programmers, distributors, and other actors of the digital industry. We may disclose information collected from or about you to such Commercial Partners (or their authorized service providers) when we are legally authorized to do so, but such disclosure is always accompanied by appropriate technical, organizational or contractual measures aimed at ensuring the integrity and security of your information (e.g., aggregation, anonymization, etc.).


      In particular, we may share information, generally in the aggregated, encrypted or anonymized form, about you with advertisers and advertising-related service providers. Some Data needs to be shared for technical reasons (e.g., to deliver advertising videos on your screen). Some Data is shared in order to make ads relevant and interesting to you or measure and improve the effectiveness of advertising campaigns. This information includes Data on your digital identifiers, devices used or online activities in relation to your use of the PrimeCutt Service, such as the websites you have visited and advertisements you have viewed. For example, we may tell an advertiser how its ads performed, or how many people viewed its ads or installed an app after seeing an ad, or provide non-personally identifying demographic information (such as a female between 25 and 30 years of age, living in London) to these advertisers to help them understand their audience or customers, but only after the advertiser has agreed to abide by strict confidentiality obligations. Note that we do not share directly identifiable information about you (such as your email address) with advertisers and advertising-related service providers.



    • 4.3. Service Providers

      Like most companies, we contract third parties to provide specialized services for us. We may share some of your Data with our service providers who provide us with specialized technical solutions, who are billing facilitators (e.g. PayPal or Payoneer), or who help us analyze and process data (e.g. provide analytic software helping us to improve ads relevancy), mange user accounts, host our websites and content, provide customer support, marketing tools (emails, on-line communication and letters) or otherwise assist us with provisions of the PrimeCutt Service.


      Our Service Providers commit to confidentiality obligations in conformity with the present Privacy Policy and contracts we sign with them.



    • 4.4. Audience Measurement Providers

      Our Commercial Partners, such as content providers and advertisers, seek to measure the performance of their videos across many platforms, including the PrimeCutt Service. Accordingly, PrimeCutt may use and permit the use on its Service of independent, industry-standard, third-party measurement software (e.g. Google analytics) that enables us or our Business Partners to include your video views in our or their measurement statistics. We may also share our own usage statistics, in anonymized or aggregated form, with these Business Partners.


      To learn more about your choices with respect to audience measurement software, please see the information we have provided in Section 9 ("Your Rights & Opting-Out").



    • 4.5. Public Authorities and Legal Counsel

      In some instances, we may be required to disclose information from or about you to public authorities or legal counsel without providing you with notice or giving you the opportunity to consent. We may disclose your information in good-faith to protect the legal rights of PrimeCutt, our affiliates or Commercial Partners, and each of our respective equity holders, directors, officers, employees, agents, and business partners; to protect the safety and security of our users of the or of third parties; to enforce our Terms of Use; to protect against fraud; for risk management purposes; and to comply with or respond to the law, a legal process, or a request for cooperation by a government entity. However, it is PrimeCutt’s policy, whenever reasonably possible and legally permissible, to promptly notify you upon receipt of a court order and/or decision issued by any competent authority pursuant to the applicable laws requesting your Data and to not produce your Data until after receipt of such court order and/or decision, so that you will have adequate opportunity to initiate appropriate legal proceedings.


      Furthermore, if you notify us that you believe your legal rights have been violated by PrimeCutt or another user of the PrimeCutt Service, we may provide the Data that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint.



    • 4.6. Third Parties in Connection with Certain Transactions

      If we sell all or part of our business, make a transfer of assets, or are otherwise involved in a change-of-control transaction, or in the event of bankruptcy, we may transfer information from or about you to one or more third parties as part of the transaction, including as part of the due diligence process. Please note that in such a case your Data would be shared only as an integral part of the PrimeCutt Service and not sold or transferred separately from the Service to third parties.



    • 4.7. Parties You Consented or When You Otherwise Choose to Share Your Data

      In addition to the sharing described in this Privacy Policy, we may share any information from or about you with any party when we have your consent or when you otherwise choose to share such information. Also, certain functions within the PrimeCutt Service may give you the option to share information about your PrimeCutt activities, for example, by email, text message, social networking, or other sharing function.






  5. DATA SECURITY AND ACCOUNT ACCESS



    • 5.1. Data Security

      The security of your Data is important to us. Our goal is to make you feel confident and safe when using the PrimeCutt Service.


      We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to only those PrimeCutt employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission, and firewalls to help prevent unauthorized persons from gaining access to your Personal Data. We also use techniques such as data aggregation to render it more difficult to link and trace information to you.


      Despite these efforts, there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the PrimeCutt Service, but we cannot guarantee the absolute security of Data at all times. We advise you to exercise caution and, in particular, to use a unique password for your PrimeCutt account, i.e. a password that you do not use for any other service you have an account with (which could prevent, in the event your PrimeCutt password confidentiality is breached, unauthorized access to these other accounts), to change your password if you suspect its fraudulent use and contact us if you notice any suspicious activities on your PrimeCutt account.



    • 5.2. Account Access

      If you have an online account with us, your Personal Data can be reviewed online from within your account settings. You can also update that information either via the account settings or by contacting us (see Section 10.6 “Contact Us” for more details).


      Your account is unique to you and protected by a user-generated password. We advise you to choose a unique and complex password, not to disclose it to third parties, and change it if you have any doubts as to its confidentiality. Do not hesitate to contact us if you observe any suspicious activity on your account.


      Please note that if you allow others to use your account (including by authorizing others to set up profiles within your account), they may be able to view information about your account (e.g. your email address) or any of the profiles created within your account (e.g. videos you have viewed). You should exercise caution while handling and disclosing your Personal Data on our Service and avoid sending it through insecure email. Please refer to the Federal Trade Commission’s website at for further information on how to protect yourself from identity theft.






  6. DATA RETENTION


    Data is stored electronically on PrimeCutt’s servers or with our cloud service providers and is kept only as long as necessary for the purposes set out in the present Privacy Policy or as otherwise required by applicable laws.


    We have a legal obligation to store some Data, such as information associated with the identity of an account holder (retained for a period of one year following the deletion of an account) or invoicing details. Once the Data is no longer needed for the intended purposes, and if its retention is not required by the applicable laws, the Data is deleted or anonymized and used for statistical purposes only. Please note that you may always exercise your right to erase your Personal Data stored in our system pursuant to the conditions set out in Section 9 below.




  7. YOUTH RESTRICTIONS AND PARENTAL CONTROL


    Children under the authorized age in their country of residence (“Minors”) are not permitted to register with PrimeCutt, i.e. are not allowed to open an account with our Service.


    The age limit that determines whether a person is a Minor depends on the country of residence and varies from 13 to 16 years of age.


    In addition, Minors should not use or access our Service without the involvement and consent of a parent or guardian.


    PrimeCutt Service is intended for the general public. It does not specifically cater to any specific age or interest group. When you visit our Service, we do not know your age. Despite lacking that knowledge, we have designed some Service features protecting young audiences. In particular, a parental control is activated by default when using our Service.


    If you are the parent or legal guardian of a Minor, and that child has somehow registered with PrimeCutt without your approval and contrary to our Terms and Conditions, please contact PrimeCutt’s support team, available 24/7 through the PrimeCutt Support to initiate an account deletion procedure. When submitting your request, please provide us with a sworn statement confirming that you are either a parent exercising full parental rights or a legal guardian of the child and indicate your full name and address, the child's full name and address, your relationship to the child and your email address. PrimeCutt will use this information only to process your request and verify that you are the child's parent or legal guardian, and for no other purposes.




  8. YOUR RIGHTS & OPTING -OUT



    • 8.1. General

      Depending on your country of residence, you may be entitled to access, correct and/or delete the Data you have provided to us, by requesting to do so through the setting of your account, or by reaching out to the PrimeCutt Support via the dedicated section. Any such request needs to be accompanied by a copy of your ID in order to allow us to confirm that you are the data subject or otherwise a person authorized to exercise these rights. Depending on the content of your request you may be asked to provide further documents as needed to confirm conformity of your request with legal requirements and identify the Personal Data to which the request pertains.



    • 8.2. Change of Privacy Settings for Promotional Communications

      You may decide not to receive promotional communications from PrimeCutt by accessing your account and clicking on "Manage Email Notifications." You may also communicate to us your decision not to receive promotional communications by clicking the "unsubscribe" link in a particular promotional message.


      Note that you cannot opt out from receiving all communications from PrimeCutt, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information necessary to using the PrimeCutt Service.


      You can choose to receive push notifications from PrimeCutt on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.



    • 8.3. Additional Information for Residents in the EEA and Switzerland

      Individuals located in the European Economic Area, have certain statutory rights in relation to their Data. Subject to statutory exemptions, you have the right to request access to your Personal Data, as well as update, deletion, correction or transfer of this information. You can do this by using the settings and tools provided in your PrimeCutt account. If you encounter troubles using the settings and tools, or if you do not have a PrimeCutt account, reach out to the PrimeCutt Support 


      Depending on the content of your request you may be asked to provide further documents as needed to confirm conformity of your request with legal requirements and to identify the Personal Data to which the request pertains.


      Furthermore, you are entitled to define and communicate to us rules applicable to your Data upon your death.


      Note that, in compliance with applicable laws, some of your Data may not be communicated, rectified or deleted despite your request to do so.


      Furthermore, PrimeCutt, in conformity with the Privacy Shield principles, undertakes to process any complaints related to its processing of Personal Data of Swiss or EEA residents. If you wish to file such a complaint, please reach out to the PrimeCutt Support Please include within your request a copy of your ID, information about your country of residence, and any information allowing us to identify your account on the PrimeCutt Service. PrimeCutt. will reply to you within 30 days.



    • 8.4. Additional Choices for California Residents

      • 8.4.1. Personal Data Processing Information under the California Consumer Protection Act (“CCPA”)

        • 8.4.1.a. General

          If you are a California resident, in addition to any other information you may find in this Privacy Policy, this section is intended to provide you with specific information required under the California Consumer Protection Act (“CCPA”). In particular, this section describes PrimeCutt’s practices regarding the collection, use, disclosure and sale of consumers’ Personal Information (hereafter referred to as “PI”) and includes an explanation of your rights regarding your own PI.


          Note that rights and obligations provided under the CCPA take effect on 1st January 2020. If you decide to exercise any of such rights your request will be considered as of that date.


          The terms “Personal Information,” “Business,” “Third Party” and “Service Provider” used in this section have the same meanings as defined in the CCPA.


          If you have an account with PrimeCutt, we identify you by the email address you use to log-in. However, if you do not have an account, in most cases, we rely on a unique online identifier to identify and recognize you.


          When you access our Service, a PrimeCutt cookie (i.e. a small text file) is dropped on your device’s browser. This cookie creates a unique online ID specific to the PrimeCutt Service and allows us to recognize you when you visit us again (“Service ID”). If you use different devices or different Internet browsers to access our Service (and unless you do so as a logged-in user, in which case we might be able to recognize you regardless of the device or browser used), you are assigned a different Service ID for each of your device/ browser combinations. In other words, if you first accessed the PrimeCutt Service using Internet Explorer on your laptop, but then visited it on your phone using Chrome you will appear to us as two distinct users. Unless you access the PrimeCutt Service as a logged-in user, any information that we might have about you is attached to that Service ID.


          Due to legal rules applicable to our activities, the lifespan of our cookies is limited to 13 months. Once the 13-month period comes to an end, the PrimeCutt cookie storing your Service ID expires. If you continue to use our Service, a newPrimeCutt cookie will be dropped on your browser and a new Service ID will be assigned to you.


          As already mentioned in this Privacy Policy, we do not cross-reference Service IDs that are assigned to you on our Service. Unless you are a logged-in user (in which case we may recognize you regardless of the number of Service IDs created for you, and we process your requests in relation to all Personal Data linked to your account), each new Service ID represents to us a new user. For that reason, if you decide to exercise any of your CCPA rights, your decision will only be applied to the Service ID we recognize you under. In particular, if you use the PrimeCutt Service on several devices or Internet browsers, your decision to Opt-Out of the sale of your PI needs to be expressed on each such device or browser.


          8.4.1.b. Collected Personal Information: Categories, Sources and the Business or Commercial Purposes It is Used for.

          We may obtain your PI either from you (directly or indirectly) or from our Service Providers or our affiliates. We receive your PI directly from you when you create an account or otherwise communicate with us or interact with our Service. We collect or generate information about you when you use our Service. Your PI may be shared with and by our affiliates if you use their services.


          Note that in order to enable the delivery of ads, certain PI may be disclosed to us by advertising partners wishing to advertise on our Service or by Service Providers we work with in the operation of the Service.


          The following categories of PI may be collected by us from or about you and used for the below-listed purposes:





















































          Category of PI Example of PI Purpose the PI is Collected for Source the PI is Collected from Categories of Third Parties with Whom PI May Be Shared
          Identifiers A real name, alias, postal address, Service ID, third party online identifier, IP address, email address, account name, a copy of official ID, or other similar identifiers To comply with a legal obligation. To achieve our business purposes You; either directly or indirectly

          Our Service Providers

          Our affiliates
          Advertising Networks companies, data analytics services providers, governmental entities,

          Our affiliates
          Commercial Information Revenues generated, Payment method details for payments made by us (to the exclusion of credit card details) To comply with a legal obligation, to achieve our business purposes You, indirectly (information generated by us based on your Content activity)

          Our Service Providers
          Content right holders, governmental entities, payment solution services providers, our affiliates
          Internet or other electronic network activity information Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement To comply with a legal obligation, to achieve our business purposes You; indirectly

          Our Service Providers

          Our affiliates
          Advertising Networks companies, data analytics providers, governmental entities, our affiliates
          Geolocation data IP address To comply with a legal obligation, to achieve our business purposes You, indirectly Advertising Networks companies, data analytics providers, governmental entities
          Electronic information Device used, language and other settings, operating system You, indirectly

          Our Service Providers

          Our affiliates
          Advertising Networks companies, data analytics providers, our affiliates
          Inferences drawn from PI to create your profile User segments based on your deduced geographic location, age and/or viewing preferences To achieve our business purposes VYou, indirectly (information generated by us based on your activities)

          Our affiliates
          Advertising Networks companies, data analytics providers, Content right holders, our affiliates.

          Note that the PrimeCutt Service is an advertising-based content hosting platform. Our business purposes include enabling you to use your PrimeCutt account, selecting content and ads showed to you on the PrimeCutt Service, delivering and monitoring the platform, processing payments that may be due to content editors, using data analytics services aimed at improving our commercial offer and providing required reporting to content editors and advertisers, ensuring security and preventing fraud, providing customer support and ensuring our compliance with legal or industry standard rules.


          The PI we collect may be shared with our affiliates, or with (i) advertising partners participating in the delivery of ads on the PrimeCutt Service (e.g. advertisers, media agencies), (ii) service providers (data analytics services), and, (iii) if required so by applicable laws, with certain public authorities. When we share your PI, we only do so to the extent needed to achieve our business purposes or to comply with the applicable laws or regulations.



        • 8.4.1.c. Categories of Collected Personal Information that Might Be Disclosed or Sold to Third Parties

          The CCPA defines the “sale” of PI as any communication of a consumer’s PI by a Business to another Business or a Third Party for monetary or other valuable consideration.


          PrimeCutt does not engage in data brokerage nor knowingly sells PI of minors under 16 years of age. As part of our regular business activities (i.e. operating an online service offering access to videos and displaying ads), your PI may be disclosed to companies we cooperate with. These companies may use such information to help us conduct our business activities (in doing so, they are our Service Providers), as well as for their own business purposes. If they do use your PI for their own business activities, our disclosure of your PI amounts to its sale.


          In addition, our advertising partners collect PI, such as digital identifiers (e.g. online identifiers, IP address), activity history (how you interact with their ads) and electronic information, when you use our Service and are shown their ads. That information is used to deliver, analyze and tailor ads you see on our Service or elsewhere. To tailor ads that may be more relevant to you, we or our commercial partners may share it with Third Parties.


          If you do not want us to sell your PI, you may decide to Opt-Out as further explained below in Section 8.4.1.e.


          The following categories of PI may be disclosed or sold by us:



































          Category of PI Can the PI be Disclosed? If so, for what purpose? Can the PI be Sold? If so, for what purpose?
          Identifiers Yes, to comply with a legal obligation, to achieve our business purposes Yes: to tailor, deliver and analyze the delivery of ads and content to you on our Service and on third parties’ services
          Commercial Information Yes, to comply with a legal obligation or to achieve our business purposes No
          Internet or other electronic network activity information Yes, to achieve our business purposes Yes: to tailor, deliver and analyze the delivery of ads and content to you on our Service and on third parties’ services
          Geolocation data Yes, to achieve our business purposes Yes, limited to city-level localization information based on your IP address: to tailor, deliver and analyze the delivery of ads and content to you on our Service and on third parties’ services
          Inferences drawn from PI to create your profile Yes, to achieve our business purposes Yes: to tailor, deliver and analyze the delivery of ads and content to you on our Service and on third parties’ services


        • 8.4.1.d. California Consumers Rights

          If you are a California resident, you have the right to request access to or deletion of your PI that we have in our records and which were collected or otherwise obtained during the 12-month period preceding your request. You also have the right to instruct us not to sell your PI to Third Parties.


          You may exercise any of these rights either directly or through an authorized representative. If you wish to make a request regarding your PI via an authorized agent, you must provide this agent with your written permission, which is to be submitted to PrimeCutt together with copies of your and your agent’s official IDs at the time of filing a request. We may ask for additional documents or information if we judge them necessary to verify the agent’s authority to act on your behalf, the extent of the authorizations you have granted and to identify your PI.


          Your choice to exercise any of the above-listed rights will not result in any discriminatory treatment.



        • 8.6.1.e. Right to Opt-Out from Sale of Personal Information

          You have the right to “opt-out” of the sale of your PI, which means that you can tell a business to stop selling your PI and to refrain from selling it in the future. Exercising your Opt-Out right does not affect previously sold PI.


          To exercise this right, click on the “Do Not Sell My Personal Information” link available within this Privacy Policy and on our Service. Note that this link may not be visible or functional if you access our Service using a non-California IP address (e.g. while accessing PrimeCutt Service from a different state or country or doing so using location-masking technologies such as a proxy or a VPN (Virtual Private Network) software). If you are a California resident and encounter problems in the exercise of your Opt-Out right, such as if you are not physically in California at the time, we invite you to contact us directly using either of the contact methods listed in Section 8.4.1.h.


          Upon exercising your right to Opt-Out, we will cease selling your PI, i.e. we will refrain from disclosing it to Third Parties for their own business purposes. We will also communicate your decision to all Third Parties to whom your PI may have previously been sold during the 90-day period preceding your request.


          Note that while we will not sell your PI once you exercise your Opt-Out right, we may still disclose such information to our business partners in order for them to help us carry out our own business activities. In these circumstances, our business partners will act as our Service Providers and they will not be allowed to use your PI for any purposes other than those we ask them to.


          We remind you that an Opt-Out decision is limited to the device and the browser used. If you use our Service on different devices or via different browsers, your Opt-Out decision needs to be communicated to us separately on each of them and renewed every time the associated Service ID is no longer active.


          Additionally, if your Service ID is no longer recognized by our Service (either because the cookie it is stored in has expired or because you or the technology you use (e.g. your Internet browser) has deleted such cookie or prevented its deployment), we will no longer be capable of either recognizing you or acknowledging that you have opted-out from the sale of your PI. We invite you to verify your registered options by accessing your CCPA settings through the “Do Not Sell My Personal Information” link and to renew the Opt-Out procedure if needed.



        • 8.4.1.f. Requests to Opt-In After Opting-Out of the Sale of Your PI

          Once you have exercised your right to Opt-Out, it is possible for you to opt back into the sale of your PI. You will be alerted if a transaction requires the sale of your PI in order to complete.


          Opting back into the sale of your PI is an easy two-step process: you just have to request to opt-in and you will then be asked to confirm your choice. You may do so by clicking the “Do Not Sell My Personal Information” link or by using any of the other contact methods described in Section 8.4.1.h below.



        • 8.4.1.g. Right to Access and / or Delete Personal Information

          In addition to the information provided in Section 8.4.1.b., you have the right to request that PrimeCutt provides you with access to the specific pieces and categories of your PI that PrimeCutt has collected, disclosed or sold during the 12 months preceding your request. This request can only be made once every 12 months.


          Additionally, you have the right to request the deletion of your PI that PrimeCutt collected or maintained during the same 12-month period.