Privacy Policy

Effective as of September 1, 2019

 

Votemo is an audience interaction platform for event organisers, television channels, format owners and production houses, streaming services and other broadcasters helping them to monetize audience interaction and engagement. We are working with clients worldwide to execute projects incorporating paid voting and commenting and it is essential that this high-availability service is accompanied by a sufficient level of trust. We ensure that your rights are protected while using our Services and we will protect the data that you share with us. To protect your privacy, Votemo has adopted these principles in accordance with the legal requirements of the General Data Protection Regulation of the European Union.

 

General

1. Who is processing my data? This privacy policy (hereinafter: Policy) has been adopted by Votemo OÜ (hereinafter: Votemo), a private limited company established under the laws of the Republic of Estonia, located at Tehnika 25-11, 10149 Tallinn, Estonia, and registered in the Estonian Commercial Register under code 14459185.

2. Is Votemo located in the EU? Votemo is registered in a member state of the European Union and is subject to the European General Data Protection Regulation (hereinafter: GDPR) and local data protection laws. This Policy shall not list nor describe all rules and principles of the GDPR, however, these rules and principles of the GDPR shall still be applicable towards Votemo and you.

3. What is this policy about? The Policy describes how and for which purposes Votemo collects, processes and distributes your personal data (meaning any data relating to an identified or identifiable natural person) provided by you or collected by Votemo when you visit the website votemo.eu (hereinafter: Site), when you use the services or products that Votemo provides or may provide in the future (hereinafter jointly: Services) or when you communicate with Votemo.

4. What if I do not agree to this policy? By using the Site or the Services or submitting data to Votemo, you are agreeing to this Policy. If you do not agree to this Policy, please do not use the Site or Services or submit data to Votemo. Please read this Policy each time before using the Site or the Services and before submitting any data to Votemo. Votemo may change this Policy unilaterally and any changes will be posted on the Site.

5. Whom does this apply to? The privacy practices set forth in this Policy apply to Votemo only. If you are linked to other web sites (including sites that offer or use the Services or which are linked on the Site or Services) or use the services of other service providers, please review the privacy policies posted by the relevant service providers.

6. What am I responsible for? You are responsible for ensuring the security of your device (restricting access, locking the device when not in use) and account (strong password, logging out after each session) which you use to access the Site and the Services and for communicating with Votemo, and limiting the access of third parties to your device and account.

 

Processing and Collection of Data

1. Votemo processes your data to the minimum extent necessary for the purposes set out in this Policy.

2. Why does Votemo process my data? Generally Votemo processes your data i) for the performance of a contract entered into (or prior to entering into a contract) between you and Votemo, ii) based on your consent or iii) to fulfil a legal obligation, but may process your data also for other reasons outlined in the GDPR to ensure lawfulness of data processing. Where Votemo processes your data based on your consent, you may withdraw the consent at any time for any reason, or no reason at all, but this will not affect the lawfulness of processing your data by Votemo before the withdrawal.

3. Votemo may also process your data under Votemo's legitimate interests. For more details, please see clauses 2.6. and 2.7. below.

4. How does Votemo receive my data? Votemo collects your data using three approaches.
   a) Firstly, when voluntarily provided by you on the Site (e.g. when you cast a vote, submit a comment, create an account, provide your data to access information or articles), in the process of using the Services (e.g. you insert your phone number to the payment window to make a mobile payment or to access content) or in any communication to (e.g. e-mails you send, chats), or interactions with, Votemo. The provision of such data by you is a requirement to enter into, or fulfil, a contract with Votemo, and without such data Votemo would not be able to provide you the Services or fulfil the contract.
   b) Secondly, when obtained by Votemo independently when you use the Site or the Services. The latter includes data which can be legally obtained using current technologies or in the course of providing you the Services, for example data regarding your operating system, web browser, mobile network provider, country of residence, IP address, mobile phone number, network connection, device, the Services that you use, how you use the Services, what content you purchase or access, how much you paid for the content etc.
   c) Thirdly, when obtained from third parties (e.g. from the content provider whose content you have purchased or accessed, or your mobile operator, or a contractual partner of the aforementioned). This may include data on your mobile phone number, what content you wish to purchase, whether your mobile payment was successful or not, why your mobile payment was unsuccessful, what you purchased, if you are eligible to receive access to certain content, if you have been refunded for a transaction, if you have not paid your mobile phone bill etc. If you have made data about yourself public or your data is available from public sources, Votemo may also process your data available from such sources in accordance with this Policy.

5. What data does Votemo process about me? Votemo's Services are constantly evolving and new Services are added regularly. So it is not possible to provide a complete list of data that we process about you, but some examples are set out below. The data that Votemo processes depends on the Services you use and differs between end users (e.g. consumers who make mobile payments or access content) and other contractual partners (e.g. content providers, mobile operators).
   a) What data does Votemo process, when I make a mobile payment or access content? With regard to end users Votemo may process data such as phone number, IP address, what content, when, and at what price did you purchase, country of residence, mobile network provider, device data, operating system, payment behavior, purchase history, payment failure reasons (e.g. insufficient funds) etc. In case an end user requests a refund from Votemo, Votemo may also process the e-mail address, name, bank account or other payment account data you provided to correctly handle the refund.
   b) What data does Votemo process, when I use Votemo's Services to monetize content? With regard to partners, if you are a private individual, then we process your personal data, and if you are a legal entity, then we process personal data of your employees and representatives. Votemo may process data such as name, names of representatives and employees, identification details (including personal identification code, date of birth), contact details, job titles, employer, country of residence, address, e-mail address, phone number, banking details etc.

6. For what main purposes does Votemo process my data? Votemo may process:

a) your identification data (e.g. your name, the names of your representatives, the legal entities you represent, identification documents, personal identification codes, date of birth) primarily to identify you;
b) your contact data (e.g. phone number, address, e-mail address, preferred language) primarily to communicate with you, to provide to you information and offers;
c) your use data (e.g. how you use the Site and Services) primarily to evaluate the performance and functionality of the Site and Services;
d) your transaction data (e.g. what content you purchased, your mobile phone number, banking details) primarily to correctly process your transactions;
e) your trustworthiness data (e.g. data about payment behavior and violations) primarily for proper risk assessment and fraud management; and
f) your location data (e.g. IP address) for determining language preferences and for statistical purposes.​​