Viewture Limited (“we,” “our,” or “us”) is committed to protecting your privacy. This PrivacyPolicy explains how your personal information is collected, used, and disclosed by ViewtureLimited. This Privacy Policy applies to our website, and its associated subdomains(collectively, our “Service”) alongside our application, Viewture Limited.

Controller for personal data
A “controller” is a person or organisation who alone or jointly determines the purposes forwhich and the way any personal data is or is likely to be processed. Unless we notify youotherwise Viewture Limited is the controller of your personal data for the purpose outlinedbelow. This privacy notice applies to the processing of personal data by us in connectionwith any:• Customers: For the provision of services by us to our customers who register to useour services.• Suppliers: For the provision of products and services to us by suppliers or serviceproviders.• Visitors: As a visitor on our website.

Types of personal data
Personal data or personal information means any information about an individual from whichthat person can be identified. It does not include data where the identity has been removed.This is known as anonymised data. Anonymised data falls outside the scope of dataprotection laws. Viewture Limited may collect, use, store and transfer different kinds ofpersonal data about you which we have grouped together:• Identity Data: includes first name, last name, username or similar identifier and title.• Contact Data: includes billing address, delivery address, email address andtelephone numbers.• Financial Data: includes bank account and payment card details.• Transaction Data: includes details about payments to and from you and other detailsfor the provision of Services you have purchased from us.• Technical Data: includes internet protocol (IP) address, your login data, browser typeand version, time zone setting and location, browser plug-in types and versions,operating system and platform and other technology on the devices you use toaccess our website.• Profile Data: includes your username and password, searches made by you, yourratings and comments, preferences, feedback and survey responses.• Usage Data: includes information about how you use our website and services.• Marketing and Communications Data: includes your preferences in receivingmarketing from us and our third parties and your communication preferences.

How we collect your personal data
Directly from you: You give us your personal data in your direct interactions with us. Suchpersonal data includes Identity Data, Contact Data, Financial Data, Profile Data, UsageData, Technical Data, Marketing and Communications Data (i) by filling in forms on ourwebsite (ii) by leaving ratings and comments (iii) by corresponding with us by email or post(iv) by calling us over the telephone.This includes personal data you provide when you:
• register to use our services.
• subscribe to our service or publications.
• request marketing to be sent to you.
• give us feedback or contact us.
• participate in our marketing or other promotional events.
• contact us if you have any concerns.
In addition, as an end customer you may voluntarily provide us with information that youhave made available on social media websites. If you provide us with any such informationwe may collect publicly available information from the social media websites, you haveindicated. You can control how much of your information on social media websites is makepublic by visiting these websites and changing your privacy settings.

Integration with YouTube API Services
Our API client integrates with YouTube API Services to allow us to evaluate YouTube channels forproduct suitability.  When using our services, we may ask you to provide us with permission toaccess data from the YouTube API Services.  By using our services, you acknowledge that weaccess and process data from YouTube, in accordance with the YouTube Terms of Service (https://www.youtube.com/t/terms). Learn more about Google's Privacy Policy at: http://www.google.com/policies/privacy.

From use of our website
• Viewture Limited gathers information and statistics collectively about visitors to theCompany's website. Analysis of this information demonstrates the most frequentlyused sections of the website and assists us in continually improving the onlineservice. You give us your personal data, which includes Profile Data, Usage Data,Technical Data and/or Marketing and Communications Data when you use ourwebsite or which we have agreed with you to use or when you review anypublications or marketing material we send you. Please see our cookies notice formore information.
Indirectly: Third-party sources: We receive Identity Data, Contact Data, Financial Data,about you from third parties when:
• we provide our Services or other parties send us your personal data to enable theprovision of those services.
• you provide your personal data to a third party for the purpose of sharing it with us.
• we receive information from a third party that provides automated fraud detectionservices to us.

Providing personal data
Where we need to collect personal data by law or under the terms of a contract we have withyou and you do not provide that information when requested we may not be able to performthe contract we have or are trying to enter into with you for example to provide you with ourservices. In this case we may have to cancel our service but we will notify you if this is thecase at the time.

How we use your personal data
Viewtures Limited will only use your personal data when the law allows us to. We will useyour personal data in the following circumstances:
• Performance of a contract: Where we need to perform the contract we are about toenter into or have entered into with you. For example when you sign up to ourservices.
• Legal obligation: Where we need to comply with a legal obligation. For example, foraccounting or legal purposes.
• Legitimate interests: Where it is necessary for our legitimate interests or those of athird party and your interests and fundamental rights do not override those interests.
• Consent: We do not generally rely on consent as a legal basis for processing yourpersonal data. Where we do rely on consent you have the right to withdraw consentat any time. Please contact us at info@viewture.com to withdraw consent. Please also see Marketing communications.

Purposes for which we will use your personal data
We have set out below in a table format a description of all the ways we plan to use your personal data and which of the legal bases we rely on to do so. We have also identified whatour legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are usingyour data. Please contact us if you need details about the specific legal ground we arerelying on to process your personal data where more than one ground has been set out inthe table below.
Purpose/Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a member for the provision of our Services.
(a) Identity
(b) Contact
Performance of a contract with you.
To respond to any enquires.
(a) Identity
(b) Contact
(a) Performance of a contract with you
(b) Necessary for our legitimate interests.
To process and deliver our Services to you including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us.
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Comms
(a) Performance of a contract with you
(b) Necessary for our legitimate interests i.e., to recover debts due to us.
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey.
(a) Identity
(b) Contact
(c) Profile
(d) Marketing andComms
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests i.e., to keep our records updated and to study howcustomers use our products/ services.
To administer and protect our business and this website including troubleshooting, dataanalysis, testing, system maintenance, support, reporting and hosting of data.
(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests for running our business, provision ofadministration and IT services, network security, to prevent fraud and in the context of abusiness reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation.To deliver relevant website content and advertisements to you and measure or understandthe effectiveness of the advertising we serve to you.
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing andComms
Necessary for our legitimate interests i.e., to study how customers use our products/Services, to develop them, to grow our business and to inform our marketing strategy.To use data analytics to improve our website, products/Services, marketing, customerrelationships and experiences.
(a) Technical
(b) Usage
Necessary for our legitimate interests to define types of customers for our products and Services, to keep our website updated and relevant, to develop our business and to informour marketing strategy
Note: Where applicable consent will be used for data analytics obtained through cookies or similar technologies. See our cookies noticeTo make suggestions and recommendations to you about our Services that may be ofinterest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Comms
Necessary for our legitimate interests to develop our products/ Services and grow our business.

Marketing communications
Viewtures Limited may send you marketing communication. You have the right to object to processing of your personal data for direct marketing purposes. You can unsubscribe fromreceiving marketing communications from us by using the unsubscribe methods contained in communications we send to you or by contacting us. See Contact us.Where you opt out of receiving marketing communications this will not apply to personal dataprovided to us as a result of registering for or using our Service, your service experience orother interactions with this website.

How we share your personal data
We may have to share your personal data with the parties set out below:• Internally: Your personal data will be used by our employees and contractors who areworking on providing your Services to you on a need-to-know basis.
• Advertising networks and analytics service providers: We may share the information that we collect with third parties such as advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose products or Services we think may interest you. Similarly, we may share portions of our log file data, including IP addresses, for analytics purposes with third parties such as web analytics partners, application developers, and ad networks. If your IP address isshared, it may be used to estimate general location and other technographics such as connection speed, whether you have visited the website in a shared location, and type of the device used to visit the website.These service providers may aggregate information about our advertising and whatyou see on the website and then provide auditing, research and reporting for us andour advertisers.Context of a sale: We may also share personal data with our current and futureaffiliated companies and business partners and if we are involved in a merger, assetsale or other business reorganization we may also share or transfer personal data toour successors-in-interest.
• Suppliers for the functioning of our Services: We may engage third-party serviceproviders to perform functions and provide services to us such as hosting andmaintaining our servers and the website, database storage and management, e-mail management, storage marketing, credit card processing, customer service andfulfilling orders for products and Services you may purchase through the website.Law enforcement bodies, regulators and other authorities: We may also disclosepersonal data about you to government or law enforcement officials or private partiesas we, in our sole discretion, believe necessary or appropriate in order to respond toclaims, legal process (including subpoenas), to protect our rights and interests orthose of a third party, the safety of the public or any person, to prevent or stop anyillegal, unethical, or legally actionable activity, or to otherwise comply with applicable court orders, laws, rules and regulations.

International transfers
How we safeguard personal data when we transfer it internationallyWe ensure a similar degree of protection is afforded whenever we transfer personal data outof the UK/EU by ensuring at least one of the following safeguards is implemented:
1. We will only transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information; or
2. We will use specific contracts approved for use in the UK/EU which give personalinformation the same protection it has in the UK/EU. For example, the use of Article46 UK/EU GDPR safeguard mechanisms to transfer personal data.

Data Security
We implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway providers database only to be accessible by those authorized with special access rights tosuch systems, and are required to keep the information confidential. We cannot, however,ensure or warrant the absolute security of any information you transmit to Viewture Limitedor guarantee that your information on the Service may not be accessed, disclosed, altered,or destroyed by a breach of any of our physical, technical or managerial safeguards.

Data Retention
Viewture Limited will only retain your personal data for as long as reasonably necessary tofulfil the purposes we collected it for including for the purposes of satisfying any legal,regulatory, tax, accounting or reporting requirements. We may retain your personal data for alonger period in the event of a complaint or if we reasonably believe there is a prospect oflitigation in respect to our relationship with you.To determine the appropriate retention period for personal information we consider the amount, nature and sensitivity of the personal information, the potential risk of harm fromun authorised use or disclosure of your personal information, the purposes for which weprocess your personal information and whether we can achieve those purposes through other means and the applicable legal, regulatory, tax, accounting or other requirements.Viewture Limited 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.

Childrens’ Privacy
We do not address anyone under the age of 13. We do not knowingly collect personal datafrom anyone under the age of 13. If you are a parent or guardian and you are aware thatyour child has provided us with personal data, please contact us. If we become aware that we have collected personal data from anyone under the age of 13 without verification ofparental consent, we take steps to remove that information from our servers.

Data Subject Rights
Under certain circumstances, you have rights under data protection laws. You can:
• Request access to your personal data: This is known as a "data subject access request"; and enables you to receive a copy of the personal data Viewture Limitedhold about you.
• Request correction of your personal data: This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal data: This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it.
Note: We may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you at the time of your request.
• Object to processing of your personal data: This is where we are processing your personal data based on a legitimate interest or those of a third party and you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to any legal claims. See also Marketing communications.
• Request restriction of processing your personal information: This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the information's accuracy
(b) where our use of theinformation is unlawful but you do not want us to erase it
(c) where you need us to hold the information even if we no longer require it as you need it to establish,exercise or defend legal claims or
(d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
• Request transfer of your personal information (“data portability”): This is where in some circumstances we will provide to you or a third party you have chosen your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: This is where we are relying on consent to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. Depending on the processing activity, if you withdraw your consent we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.
• Automated decision making: This is where decisions are made about you byautomated means.We do not carry out automated decision making.

Keeping personal information accurate and current
It is important that the personal data we hold about you is accurate and current. Please keepus informed if your personal data changes during your relationship with us. If you wish toupdate your personal data please contact us. See Contact us.

Carrying out your data subject rights
You will not have to pay a fee to access your personal data or to exercise any of the otherrights. However, we may charge a reasonable fee if your request is clearly unfounded,repetitive or excessive. We may need to request specific information from you to help usconfirm your identity and ensure your right to access your personal information or to exerciseany of your other rights. This is a security measure to ensure that personal information 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.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. If you wish to exercise any of the rights set out above, please contact us at info@viewture.com

Concerns and complaints
We would appreciate the chance to deal with your concerns in the first instance. Please see Contact us section. If you have unresolved concerns and you live or work in the UK or believe that a personal data breach happened in the UK you have the right to complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). If you live or work outside the UK or you have a complaint concerning our personal data processing activities you may lodge a complaint with another supervisory authority.

Links To Third-Party Services
We may display, include or make available third-party content (including data, information,applications and other products services) or provide links to third-party websites or services("Third- Party Services"). You acknowledge and agree that Viewture Limited shall not be responsible for any Third-Party Services, including their accuracy, completeness, timeliness,validity, copyright compliance, legality, decency, quality or any other aspect thereof. ViewtureLimited does not assume and shall not have any liability or responsibility to you or any otherperson or entity for any Third-Party Services. Third-Party Services and links are providedsolely as a convenience to you and you access and use them entirely at your own risk andsubject to such third parties' terms and conditions.

Links to Other Websites
This Privacy Policy may contain links to other websites not operated or controlled by Viewture Limited. We are not responsible for the content, accuracy or opinions expressed insuch websites, and such websites are not investigated, monitored or checked for accurac yor completeness by us. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on our platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or other methods to collect information about you.

Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they accurately reflect our Service and policies. Unless otherwise required by law, we will notify you for example, through our Service before we make changes to this Privacy Policy and give you an opportunity to review them before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy Policy. If you donot want to agree to this or any updated Privacy Policy, you can delete your account.

Additional Information for California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect and how we use it, the categories of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have explained above. Note that under the CCPA we will provide you with this information contained within the last 12-month period preceding your request. We are also required to communicate information about rights California residents have under California law. You may exercise the following specific rights:
 Right to Know and Access: You may submit a verifiable request for informationregarding the: (1) categories of Personal Information we collect, use, or share; (2)purposes for which categories of Personal Information are collected or used by us;(3) categories of sources from which we collect Personal Information; and (4) specificpieces of Personal Information we have collected about you.
• Right to Equal Service: We will not discriminate against you if you exercise yourprivacy rights.
• Right to Delete: You may submit a verifiable request to close your account and wewill delete Personal Information about you that we have collected.
• Non-Sale of Data: Request that a business that sells a consumer's personal data notsell the consumer's personal data.We do not sell the Personal Information of our users. If you want us to carry out your rightsplease see the section on Carrying out your data subject rights.

Contact us
If you would like more information about the way we manage personal data that we holdabout you please contact us at:Email address: info@viewture.com