PRIVACY POLICY

Last Modified: Jan 7, 2019

This is the privacy policy (“Privacy Policy”) for the specific Internet website, application or other interactive service (“Site,” “we,” “us,” or “our”) provided by Richnroll Digital Services Co.,Ltd. (“Rich”) that contains an authorized link to this Privacy Policy, which, for the purposes hereof, shall include any information submitted through third party websites directly linked from the Site that permit online submission to Viacom, as further discussed herein.  Notwithstanding the foregoing, all information and data submitted through any third party website will also be subject to such third party’s privacy policy.  For purposes of clarity, this Privacy Policy does not apply to information collected offline or otherwise outside of scope of the Site, as set forth above.

By using the Site, you agree to accept the terms of this Privacy Policy. Rich may amend this Privacy Policy from time to time. If Rich makes any substantial changes in the types of information Rich collects or how Rich uses such information, Rich will inform you of such changes in accordance with the terms of this Privacy Policy.

When This Privacy Policy Applies

This Privacy Policy applies whether you are accessing the Site via a personal computer, a mobile device or any other technology or devices now known or hereafter developed or discovered (each, a “Device”) and whether you are accessing the Site as a registered user or other user of the Site.  This Privacy Policy governs only the Personal Information and Other Information (as those terms are defined below) collected by the Site and does not cover any such information collected in any other manner or by any other website offered by Rich and/or any affiliates that Rich directly or indirectly owns or controls (collectively, “Affiliates”) or collected by any other company, unless specifically stated. Such information collection may be governed by separate privacy policies or notices.

This Privacy Policy, as amended from time-to-time, will remain in full force and effect even if your use of or participation in the Site or any particular service, feature or function offered through the Site terminates, expires, ceases, is suspended or deactivated for any reason.  If you do not agree with this Privacy Policy, please do not access the Site or any features or services offered through the Site.

Collection and Use of Personal Information and Other Information

When we use the term “Personal Information” we mean information that would allow someone to identify you or contact you, such as your full name, postal address, e-mail address or telephone number.   When we use the term “Other Information”, we mean any information other than Personal Information that may be collected about you (Personal Information and Other Information, together, the “Information”).

a.   Information We Collect that You Provide Us. 

i. In Connection with Certain Features and Functions. We may also provide you with access to certain features or functions that we may offer on the Site, such as message boards. To sign up for or participate in these features or functions, you may be required to provide us with certain Information about you in order for us to personalize and/or allow you to use such features and functions.

b.   Information Collected Through Use of Cookies and Other Tracking Technologies. 

“Cookies” (which may be html files, Flash files or other technology) are text files that help store user preferences and activity. “Web beacons” (also known as image tags, gif or web bugs) are small pieces of code used to collect advertising data, such as counting page views, promotion views or advertising responses.  The Site and/or third parties may use “cookies”, “web beacons” and other similar tracking technologies (collectively, “Tracking Technologies”) to collect Other Information automatically as you browse the Site and the web.

By visiting the Site, whether as a registered user or otherwise, you acknowledge, understand and hereby agree that you are giving us your consent to track your use of the Site through these Tracking Technologies.

We use Tracking Technologies to help tailor our content, allow users to move between associated sites without logging into each site, understand Site and internet usage, improve or customize the content, offerings or advertisements on this Site, personalize your experience on this Site (for example, to recognize you by name when you return to the Site), understand your interactions with email messages (such as the links clicked on and whether the messages were opened or forwarded), save your password in password-protected areas, save your online game or video player settings, enable you to use shopping carts on the Site, help us offer you products, programs or services that may be of interest to you, deliver relevant advertising, maintain and administer the Site and for other purposes described in the “Use of Information”, Other Information Collected by Us.  These Tracking Technologies collect “click stream” data and additional Other Information regarding your visits to the Site (such as your visits to the Site’s webpages, use of our features and purchasing history or preferences), may collect such Other Information across multiple sessions on this Site and other websites offered by Affiliates and may also collect your IP address or some other identifier unique to the Device you use to access the Site (“Identifier”).  An Identifier is automatically assigned to any Device you use to access the Site.  Your Personal Information is not collected as part of this process but we may associate Other Information collected by Tracking Technologies with Personal Information.

This Site may additionally use a variety of third party advertising networks, data exchanges, traffic measurement service providers, marketing analytics service providers and other third parties (collectively, “Third Party Advertising Service Providers”) to, for example, serve advertisements on the Site, facilitate targeting of advertisements and/or measure and analyze advertising effectiveness and/or traffic on the Site (“Targeting Services”).  These Third Party Advertising Service Providers may enable us to display advertisements based on your visits to the Site and other websites you have visited.  Targeting Services enable us to, among other things, help deliver advertisements or other content to you for products and services that you might be interested in, to prevent you from seeing the same advertisements too many times and to conduct research regarding the usefulness of certain advertisements to you.

These Third Party Advertising Service Providers do not have access to Tracking Technologies set by the Site except to the extent necessary to provide services to the Site.  The Third Party Advertising Service Providers and other third parties may themselves set and access their own Tracking Technologies on your Device if you choose to have Tracking Technologies enabled in your browser (or, for Flash cookies, if you have not removed them) and/or they may otherwise collect or have access to Information about you and your online activities over time and across different websites when you use the Site.

c.   Use of Information.

i.  Personal Information.  As set forth in this Privacy Policy, we may sell, rent, lease, disclose or otherwise share Personal Information with Affiliates.  We and Affiliates, use the Personal Information we collect from you in a variety of ways, including:

  • Processing your registration with the Site, such as verifying that your e-mail address is active and valid,
  • Contacting you regarding the administration of your account, any services, features or functions you have enrolled in or registered to use,
  • Allowing you to participate in the public areas and/or other features of the Site,
  • Responding to your questions or other requests,
  • Contacting you regarding your use of the Site, for informational purposes related to the Site or, in our discretion, regarding changes to the Site’s policies,
  • Improving the Site or our services and for internal business purposes,
  • Saving your password or other Personal Information, so you don’t have to re-enter it each time you visit the Site,
  • Otherwise to maintain and administer the Site and,
  • For other purposes disclosed at the time you provide Personal Information or Other Information.

ii.  Other Information Collected By Us We, and/or Affiliates, use the Other Information we collect from you in a variety of ways, including:

Keeping count of your return visits to the Site or our Affiliates’ or partners’ sites;

Accumulating and reporting aggregate, statistical information in connection with the Site and user activity;

Determining which features, webpages, products and services users like best to, among other things, help us operate the Site, enhance and
improve our services and the Site and display advertising and marketing information;

Preparing statistics reports;

Allowing you to participate in the public areas and/or other features of the Site;

Improving the Site or our services and for internal business purposes;

Tailoring your experience on the Site and/or otherwise customizing what you see when you visit the Site;

Saving certain Other Information for use on your return visits to the Site;

Otherwise to maintain and administer the Site;

For other purposes disclosed at the time you provide the Other Information.

iii. Other Information Collected by Third Party Advertising Service Providers.  The use of Tracking Technologies by Third Party Advertising Service Providers is within their control and not ours.  Even if we have a relationship with the Third Party Advertising Service Provider, we do not control their websites or their policies and practices regarding your Information and you should be aware that different rules might apply to the collection, use or disclosure of your Information by third parties in connection with their advertisements or promotions and other sites you encounter on the Internet.  This Privacy Policy does not cover any use of Information that a Third Party Advertising Service Provider may directly collect from you.  Use of Third Party Advertising Service Providers’ Tracking Technologies is governed by the Third Party Advertising Service Providers’ own specific privacy policies and not this Privacy Policy.  However, please see “Opting-Out of Certain Uses of Information Collected by Tracking Technologies” Section below for more information on how to opt-out of the collection and/or use of Information collected by certain Third Party Advertising Service Providers.

Sharing and Disclosure of Personal Information and Other Information

a.     Sharing and Disclosure of Personal Information.  Rich does not sell, rent, lease, disclose or otherwise share your Personal Information with third parties for those third parties’ marketing purposes.

b.    Sharing and Disclosure of Other Information. Rich may sell, rent, lease, disclose or otherwise share Other Information, such as aggregated user statistics, with third parties.

c.     Disclosure of Certain Information in Postings Intended to Be Disclosed. Certain Personal Information associated with a Posting may be intended for disclosure (“Posting Information”), such as username. We will disclose Posting Information in connection with the display of, and other services relating to, such Posting.

d.    Operational Service Providers.  We also have the right to disclose your Personal Information to third parties for the purpose of administering and maintaining the Site’s services, features, functions and operations. We will refer to these third parties as “operational service providers”. We use operational service providers to efficiently provide the full range of content, activities, services, features and functions we bring you and we disclose your Information to operational service providers for the purpose of providing services to us.

e.    Disclosure to Certain Other Third Parties.  In addition, Rich may share your Personal Information as set forth in this Privacy Policy or in the following limited circumstances:

·         When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to subpoenas, court orders or legal process) or if requested by a governmental agency or other authority as part of an investigation;

·         If we believe your actions violate any law, rule, regulation and/or the Terms of Use, including, without limitation, this Privacy Policy;

·         If, in our sole discretion, we believe such disclosure to be necessary or appropriate: to investigate or resolve possible problems or inquiries; to protect our business and assets or the rights, property or safety of the Site, the Affiliates, or any of its or their licensors, suppliers, customers, users, or any other party; to limit our legal liability; to defend our interests; to enforce this Privacy Policy or the Terms of Use and/or to comply with our legal and regulatory obligations or requests by law enforcement agencies or governmental authorities, including, without limitation the Equal Employment Opportunity Commission, the Office of Federal Contract Compliance Programs and similar state and local regulatory agencies; and/or

·         In the event of a bankruptcy, merger, acquisition, sale, transfer of control, joint venture or other business combination or corporate change involving us or our Affiliates.

Protection of Information

While no data transmission over the Internet is 100% secure from intrusion, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your Information.  However, regardless of our efforts and the Device you use to access the Site, it is possible that third parties may unlawfully intercept or otherwise access transmissions or private communications over an unsecured transmission.  We also limit access to the Site by our own employees to those individuals who are authorized for the proper handling of such information and any employee found violating our standards of security and confidentiality will be subject to our disciplinary processes.  We request that our Operational Service Providers follow similar standards of security and confidentiality.

Phishing.  Phishing attacks attempt to steal consumers’ personal identity data and financial account credentials.  “Phishers” use ‘spoofed’ e-mails to lead consumers to counterfeit websites designed to trick recipients into divulging Information such as credit card numbers, account usernames, passwords and social security numbers.  WE DO NOT SEND EMAILS ASKING YOU TO PROVIDE OR CONFIRM CREDIT CARD NUMBERS, SOCIAL SECURITY NUMBERS OR YOUR USERNAME OR PASSWORD!  If you receive such email communication, please forward it immediately to the Site’s Privacy Administrator by clicking here, and sending a communication to Rich through the “Contact” Page with the subject of “Privacy”, and then immediately delete the fraudulent email from your computer.

Changes to this Privacy Policy and Notice

We reserve the right to revise this Privacy Policy at any time by posting an updated Privacy Policy without advance notice to you.  Such revisions shall be effective immediately upon posting.  Notice of material changes will be posted on the Site’s homepage and/or will be provided by e-mailing you or notifying you upon login about these changes; the form of such notice is at our discretion.  However, we encourage you to check this Privacy Policy and Terms of Use often for updates.

This Privacy Policy was last modified on the date indicated above and is effective immediately. Copyright © 2019 Rich Digital Agency. – All Rights Reserved.