Augustus Media Privacy Policy

This privacy policy (Privacy Policy) describes how Augustus Media Holdings LTD, its subsidiaries, affiliates, brands, and entities that it controls, including ‘Lovin’ and ‘Smashi’ brands* (collectively, “Augustus Media,” ‘AMH’, “we,” or “us”) collect, use, disclose, and store Personal Data we obtain through your access and use of the websites, social media accounts, content, information, features, tools, resources, online offerings, applications, and other products and services produced, maintained, distributed, or provided by,  Augustus Media, or affiliated with us, your interactions with us, and through our normal business activities (collectively, the “Services”).  Our Services include your interactions with our websites, apps, social media accounts, customer service representatives, and our other employees. Augustus Media respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

*Augustus Media are the sole License IP rights holders for the ‘Lovin’ media brand in the following territories UAE, Bahrain, Qatar, Kuwait, Oman, Saudi Arabia, Yemen, Jordan, Lebanon, Syria, Palestine, Sudan, Egypt, Pakistan, Iran and Iraq.

Types of Data We Collect: “Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data and Anonymous Data, as described below.

Account Security

You are solely responsible for (i) maintaining the security of your Account and (ii) all activity that occurs under your Account. You must notify us immediately if you suspect any unauthorized access to or use of your Account. If you forget your account login information, you may request that we send it to the email address associated with your Account.

Information That We Collect

Augustus Media Holdings, and vendors acting on AMH’s behalf, may collect Personal Data from and about you as follows:

Account-related Information: To create an Account, you must provide certain information, including Personal Data such as your email address and a password. We may allow you to submit additional information including an avatar. You may provide other information about yourself in connection with surveys, contests, special offers, customer support inquiries, and other communications with us.

Usage Information: We collect information about your use of the AMH Services, including your accessing, viewing, and downloading of Augustus Content.

Information Collected Automatically: We collect information about your use of our websites and Apps. This may include your activities, your IP address, your browser type, your Internet service provider (ISP), referring/exit pages, your operating system or device type, date/time stamps, and related metadata. How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our website. Flash LSOs. When we post videos, third parties may use local shared objects, known as “Flash Cookies,” to store your preferences for volume control or to personalize certain video features.

Mobile Device and Services: If you use our services on your mobile device, including through our Smashi app and Lovin App, we may collect the unique device id number. We may also collect non-personal information from your mobile device if you have downloaded our Apps. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include how you use the Smashi or Lovin Apps, and information about the type of device you use. In addition, in the event one of our Apps crashes on your mobile device, we will receive information about your mobile device model software version and device carrier, which allows us to identify and fix bugs and otherwise improve the performance of the app. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Third-Party Data Collection

Third-Party Platforms: When you use an application that runs on a third-party platform (e.g., iOS, Etisalat E-Vision, etc.), the provider of that third party platform may collect Personal Data or other information about you and your use of our Apps.

Analytics and Advertising: We may use third-party analytics services to collect data about usage of our services. We may allow third-party advertising companies (including advertising agencies, networks, and delivery vendors) to collect data regarding advertisements that they may place on our websites. Third-party analytics providers and advertising companies may use cookies to track your activities. Some advertising companies may be members of the Network Advertising Initiative, which offers a single location to opt-out of ad targeting from member companies.

How We Use Your Information

Augustus Media may use the information that we collect about you to:

• Fulfil your orders and deliver content and other services to you;
• Provide customer support to you;
• Analyze how our services are being used;
• Communicate with you;
• Verify your eligibility to make purchases and participate in offers;
• Collect any debts, prevent fraud, and otherwise protect the integrity of our systems;
• Enforce our legal rights;
• Perform any functions described at the time of collection; and
• Otherwise operate our business.

Disclosures to Third Parties

AMH may disclose information about you as follows:

Authorized Service Providers: We may disclose your information to service providers involved in operating our business. This includes payment providers, email service providers, content delivery networks, cloud storage providers, analytics companies, and professionals such as accountants and lawyers. These service providers are required not to use your Personal Data other than to provide the services requested by Augustus Media.

Legal Situations: We may disclose your information when we believe in good faith that (i) disclosure is required by a search warrant, subpoena (whether criminal or civil), civil investigative demand, court order, or a request for cooperation from a law enforcement or other government agency; (ii) disclosure is appropriate and necessary to report a suspected crime (including any case of suspected child exploitation) or prevent physical harm to an individual or property; (iii) disclosure is appropriate and necessary to enforce our rights; and (iv) disclosure is required by law. Nothing in this Privacy Policy shall be deemed to create any third party right, and we reserve the right to object to any third-party requests for information in appropriate circumstances.

Affiliates and Corporate Transactions: We may disclose your information to our parent companies in connection with operating our business. In the event Augustus Media or its subsidiary companies are involved in a business transition that involves the sale, merger, or divestment of Augustus Media or its subsidiary companies, we may disclose any information about you to the acquiring entities. The transferred information will remain subject to the provisions of this Privacy Policy, as updated.

To the Public: We may create Anonymous Data records from Personal Data. We may publicly disclose Anonymous Data and aggregated user statistics and other information.

Emails

When you create an Account, you may receive certain emails:

Transaction emails: When you first register with Augustus or one of its brands, we may send you a welcome email that provides information about the Service and your Account. We may also, from time to time, send you other emails concerning your Account status. You may not opt-out of receiving transactional emails.

Newsletters: We may send you newsletters and other emails about new or upcoming products, services, or offers. If you decide you no longer wish to receive these emails, you may opt-out as instructed in each email or in your Account settings.

Security Measures

We use security measures to protect the loss, misuse, and unauthorized alteration of the information under our control. Please be advised, however, that we cannot guarantee that our security measures will prevent disruptions or unauthorized access from occurring.

Your Privacy Choices

You may choose not to provide us with certain information. If you fail to provide us with certain information, you might not be able to use certain services that we offer.

You may change your account information or close your Account at any time by logging into your Account and selecting Account setting. If you close your Account, you may lose access to the Augustus Content that was available to you through your Subscription to the Augustus Brand Services. We may preserve your account information (i) for a period of time in case of accidental deletion or in case you change your mind; and (ii) where we believe in good faith that preservation is required by law or necessary to enforce our rights.

You can stop all collection of information by the Augustus Brand Apps by uninstalling the Smashi App or Lovin App from your device. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Using our Services from Outside of the Middle East

This Privacy Policy is intended to cover collection of information on or via our service from residents of the Middle East. If you are using our services from outside the Middle East, please be aware that your information may be transferred to, stored, and processed in the Middle East where our servers are located and our central database is operated. The data privacy and protection laws of the Middle East might not be as comprehensive as those in your country. By using our services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Policy, and you consent to such transfer.

Children’s Privacy

Consumers: In order to create an Account with AMH’s brands, an individual must be at least 13 years of age. Children older than 13 but younger than 18 must have the consent of the child’s parent or guardian to use the Services.

If you believe that we might have any Personal Data from a child under 13, please contact us at compliance@weareaugustus.com.

Third-Party Services

We may provide links to third-party websites and applications. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or applications, or to any collection of your Personal Data after you click on links to such outside websites. We have no control over such services and therefore refer you to their privacy policies for Personal Data or other information on their respective privacy practices. The links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content or websites.

Security of Credit Card

For online payments of your Subscription, we use the payment services of PayFort, Inc. (https://www.payfort.com/). We do not process, record or maintain your credit card or bank account information. For more information on how payments are handled, or to understand the data security and privacy afforded such information, please refer to https://www.payfort.com/uw/rak/index.html

For mobile payments of your Subscription, we use the payment services of T-Pay, Inc. (https://tpay.com/en ). We do not process, record or maintain your mobile provider account information. For more information on how mobile payments are handled, or to understand the data security and privacy afforded such information, please refer to https://tpay.com/en/terms-of-use .

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected 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 the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

As per country jurisdiction.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Updates

We may update this Privacy Policy from time to time by posting an updated Privacy Policy on the Augustus website. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at www.weareaugustus.com/privacy, and we will change the “Last Updated” date above. Your continued use of our services constitutes your agreement to the updated Privacy Policy on a prospective basis.

Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at:

Augustus Media Holdings Ltd, 2406 ResCo-work 02, 24thFloor, Al Sila Tower, Abu Dhabi Global Market Square,  Al Maryah Island, Abu Dhabi, United Arab Emirates

Compliance@weareaugustus.com