Cinnamon

Privacy Policy

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US version  EU versionPrivacy PolicyEffective September 15, 2020 Cinnamon Technologies, Inc (“we”, “us” or “Cinnamon”) cares about protecting the personal information of our customers, visitors and users (“you” or “Users”) who use our Services (as defined in the Terms of Service available at https://cinnamon.video/settings/terms-of-service). We consider your privacy to be very important and have created our Privacy Policy to provide you with information regarding the collection, use and disclosure of your information when accessing our Services. Your information will not be shared or used by anyone except as described in this Privacy Policy. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy applies to all of the services offered by Cinnamon and its affiliates and constitutes an integral part of our Terms of Service. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy shall have the same meanings as assigned to them in our Terms of Service, accessible on our Services. This Privacy Policy is meant to help you understand what information we collect, why we collect it, and how you can update, manage, export, and delete your information. The California Consumer Privacy Act (“CCPA”) requires a description of data practices using specific categories. The below uses links to these categories to organize the information in this Privacy Policy. <ul> <li> We explain the categories of information Cinnamon collects and the sources of that information in Categories of Personal Information we collect. </li> <li> We explain how Cinnamon uses information in Why we collect data. </li> <li> We explain when Cinnamon may share information in Sharing your information. Cinnamon does not sell your Personal Information. </li> <li> We explain purpose for which Cinnamon may share your data in Business purposes for which information may be used or disclosed. </li> <li> We describe the choices you have to manage your privacy and data across Cinnamon's services in Your privacy rights. </li> <li> We explain the categories of information Cinnamon transferred to third parties in Categories of Personal Information transferred to third parties. </li> </ul> INFORMATION WE COLLECT Information you provide to us The type of information collected depends on your interaction with us. For instance, for persons without an account, we collect basic usage data like IP address, user-agent, and pages you access on our server as part of our Services. When you create a Cinnamon account, you provide us with information that personally identifies you, such as your name, email address, or billing information, or other data that can be reasonably linked to such information by Cinnamon, such as information we associate with your Cinnamon account that includes a password (“Personal Information”) or other data expressly stated in this Privacy Policy. You can also choose to add a phone number or your payment information to your account. You will need your email address and a password to sign in to your account, your name is associated with your account profile, and is displayed when you access your account or submit any material on our Services. Although we generally avoid storing and using your Personal Information as much as possible, we process such information in order to protect our legitimate interest in providing our Services and protecting the security of your account. We also process your email address and name for the purpose of providing you with important information about your products, apps or account, which may include safety information or material changes to this Privacy Policy or our Terms of Service, and providing you an opportunity to engage with other users. We also collect the Content you create, upload, or receive from others when using our Services. If you subscribe to our Services, we collect information about the subscription. For payments to and from Cinnamon, we use Coil and other third party wallet providers completely separate from the Cinnamon Services, such as Uphold or GateHub. Refer to the Coil and the applicable wallet provider's privacy policy to see what data they collect. Information we collect as you use our services <ul> <li> Your apps, browsers &amp. devices. We collect information about the apps, browsers, and devices you use to access our Services. This will help us provide features like automatic product updates. The information we collect includes browser type and settings, device type and settings, unique identifiers, IP address, operating system, mobile network information, internet service provider, application version number, your device's regional and language settings, and other similar information. This data also includes MAC address, device advertising Id (e.g., IDFA or AAID), and other device identifiers. We also collect information about the interaction of your apps, browsers, and devices with our Services, such as crash reports, system activity, and the date, time, and referring URL. </li> <li> Your activity. We collect information about your activity in our services, which we use to do things like recommend Content you might like. The activity information we collect may include: features you use on the Cinnamon Service, Content you view, pages you visit on the Cinnamon Service, terms you search for. whether you follow links in emails from Cinnamon, advertisements for the Services you view, characteristics of any subscription you purchase from Cinnamon, the time of day you use the Services, your referring and exiting pages on the Services, interaction with other Users, activity on Third-Party Material that use our Services. </li> <li> Your location information. We collect information about your location when you use our Services, in order for us or our third-party service providers to provide you with location-based Services and control access to Services based upon the User's geographical location. We process this information in order to fulfil our legal and contractual obligation. The types of location data we collect depend in part on your device and account settings. The location data we collect may imply imprecise location data (e.g., location derived from an IP address or data that indicates a country, city or postal code). </li> </ul> Information from other Sources In some circumstances, Cinnamon also collects information about you from publicly accessible sources, information that other people provide when they use our Services or information on Other Social Apps when you reference our Services or grant permission to Cinnamon to access your data on one or more of these services. (For example, if you add your YouTube channel to our Services, YouTube will ask you to grant us limited access to your YouTube account so we can pull the channel information to our service. We may also collect information about you from trusted partners, including our marketing partners, security partners and advertisers partners. WHY WE COLLECT DATA Provide, improve, customize and modify our Services We use the information we collect to effectively provide our Services, for instance, we process your email address and name for the purpose of providing you with important information about your account and providing you an opportunity to engage with other users. If you opt-in for the emotion detection feature, we use our emotion recognition technology to collect anonymized data that was collected and processed by your device, and that identifies and describes the emotions you exhibit while interacting with Content on our Services. We do not collect or process any Personal Information with our emotion recognition technology. We also use your information to maintain and improve our Services, such as improving tracking outages or troubleshooting issues that you report to us. We use the information we collect in existing Services to help us develop new ones. We use the information we collect to customize our Services for you, including providing recommendations and personalized Content. Communicate with you We use the information we have to send you marketing communications, communicate with you about our Services, and let you know about our policies and terms. We also use your information to respond to you when you contact us. Measure performance and Protect Cinnamon, our users, and the public We use data for analytics and measurement to understand how our Services are used. For example, we analyze data about your visits to measure and evaluate site usage behavior, such as scrolling activity, pages visited and actions taken on the site and use to optimize our Services product design. We also use information to help improve the safety of our Services, such as detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm Cinnamon, our users, or the public. We'll ask for your consent before using your information for a purpose that isn't covered in this Privacy Policy. We do not share information that personally identifies you with advertisers, such as your name or email, unless you ask or allow us to. HOW WE COLLECT DATA We use different technologies to collect, process and store your information. These technologies include: <ul> <li> Log Files. A log file is a file that records events that occur in connection with your use of the Services, such as your service use data. </li> <li> Cookies. A cookie is an industry-standard small data file stored on your device that acts as a unique tag to identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Persistent cookies help with personalizing your experience, remembering your preferences, and supporting security features. Persistent cookies may remain on your device for extended periods of time, and generally may be controlled through your browser settings. </li> <li> Third Party. We may embed third party scripts or put embeds in the page that send requests to external sites which may allow third parties to drop and read cookies on your browser. We cannot read or alter the cookies dropped on your browser by external sites. Your browser may allow you to disable cookies from third party sites. </li> <li> Others. Other technology used include pixel tags, web beacons, local storage, algorithms and other similar tools on our Services or in our email messages. </li> </ul> DELETING AND RETAINING YOUR INFORMATION We retain the data we collect for different periods of time depending on a case-by-case determination that depends upon things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. You would be able to delete some data such as Content or your activity information. Some other data is deleted or anonymized automatically immediately or after a set period of time. For instance, data from our emotion recognition feature is collected on User’s device and deleted without any information sent to our servers. We also keep some data until you request that we delete your Cinnamon account, such as information about how often you use our services while for some data, we retain for longer periods of time when necessary for legitimate business or legal purposes, such as security, fraud and abuse prevention, or financial record-keeping. To delete your account at any time, please contact us at compliance@cinnamon.video and we will delete your account. Please note that we may require additional information from you to allow us to confirm your identity prior to deleting your account. When we delete your account, we will follow a deletion process to make sure that your data is safely and completely removed from our servers or retained only in anonymized form. Since we try to ensure that our services protect information from accidental or malicious deletion, there may be delays between when you delete something and when copies are deleted from our active and backup systems. If you posted something by accident and are unable to remove it yourself, please contact us and we will make a reasonable effort to remove it from public view if we can. When we delete your account, we delete Content you have posted, including all Shorts made from Content you posted and you won't be able to recover that information later. However, information that others have shared about you isn't part of your account and won't be deleted. If you don't want to delete your account but want to temporarily stop using the Services, you may deactivate your account instead. YOUR PRIVACY RIGHTS Managing, reviewing, and updating your information You can decide what types of information you would like saved in your account. When you’re signed in, you can always access, review, update, rectify, port and delete your information by visiting the settings of the Services you use. You can also manage your preference about Content shown to you on Cinnamon and on sites and apps that partner with Cinnamon. You can also control what other Users see about you across Services. You can export a copy of content in your Cinnamon account if you want to back it up or use it with a service outside of Cinnamon. You may also access, update, or remove certain account information that you have voluntarily submitted to us through the Cinnamon Service by sending an email to the email address set forth in the section entitled “Contact Us” below. We may require additional information from you to allow us to confirm your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You can also request to remove your Content from specific Cinnamon Services based on applicable law. California residents and European data subjects have additional rights as set forth below. Tracking Technology Choices You can also control the information Cinnamon collects, whether or not you’re signed in to a Cinnamon Account, by configuring your browser. Most browsers accept cookies by default. You can configure your browser, by changing its settings, to decline or delete cookies. If you use multiple browsers on your device, you will need to instruct each browser separately. Also, your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what website and app operators should do with regard to these signals. Accordingly, we do not monitor or take action with respect to “Do Not Track” signals or other mechanisms. For more information on “Do Not Track,” visit https://www.allaboutdnt.com. Please be aware that if you disable or remove tracking technologies, some parts of our Services may not function correctly. SHARING YOUR INFORMATION When you share your information Many of our Services let you share information with other people, and you have control over how you share. For example, you can share Content on Cinnamon publicly or you can decide to share your Content only with Subscribed Viewers. Also, real time communication is a feature available on some of our products that enables you to communicate with other Users of our Services. Alternatively, you may be able to send a link to people of your choice that allows them to see your Content. Remember, when you share information publicly, your content may become accessible through search engines, and you may not always be able to edit or delete such information. however, California residents and European data subjects have specific rights as set forth below. When you’re signed in and interact with some Services, like leaving comments on a Cinnamon content, your name and photo may appear next to your activity. When Cinnamon shares your information We do not share your Personal Information with companies, organizations, or individuals outside of Cinnamon except in the following cases <ul> <li> With your consent - We will share Personal Information outside of Cinnamon when we have your consent. </li> <li> For external processing - We provide Personal Information to our affiliates, partners, service providers and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. For instance, we may use a third party to assist in sending emails. Those services track the activities associated with these emails, such as whether they were opened, whether links in the emails were clicked on. We also use a third-party service provider, Coil, to collect payment from Subscribed Viewers and provide payment for monetized Content. We also use Amazon Web Services to operate and to administer our Services. We also provide aggregated statistics and insights that help Users understand how people are engaging with their Content on the Services. If you choose to register to use the Services using your social network account details (e.g. Facebook, Twitter, Instagram, Google), you provide us or allow your social network to provide us with your username and public profile. We will likewise share certain information with the relevant social network such as your app ID, access token and the referring URL. Also, where you opt to share content on social media platforms, the video, username and any text associated with the post will be shared on that platform or, in the case of sharing via instant messaging platforms such as Whatsapp, a link to the content will be shared. </li> <li> For legal reasons - We will share Personal Information outside of Cinnamon if we have a good-faith belief that access, use, preservation, or disclosure of the information is reasonably necessary in order to comply with a valid court order, subpoena, legal order, legal process, or other legal obligation. to enforce our Terms of Service, any of our terms and conditions or our policies. Detect, prevent, or otherwise address fraud, security, or technical issues. as necessary to pursue any available legal remedies or defend legal claims. or Protect against harm to the rights, property or safety of Cinnamon, our users, or the public as required or permitted by law. </li> </ul> We may share non-personally identifiable information publicly and with our partners — like publishers, advertisers, developers, or rights holders. For example, we may share information publicly to show trends about the general use of our services. If Cinnamon is involved in a merger, acquisition, or sale of assets, we'll continue to ensure the confidentiality of your Personal Information and give affected users notice before Personal Information is transferred or becomes subject to a different privacy policy. KEEPING YOUR INFORMATION SECURE We use reasonable measures to help protect your information and maintain reasonable administrative, physical, and technical security safeguards against loss, theft, misuse and unauthorized access, disclosure, alteration and destruction of your information. We also use the information we collect to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Services. THIRD PARTIES Third Party Services The Services contains content from and hyperlinks to websites, locations, platforms, and services operated and owned by third parties (“Third-Party Services”). These Third-Party Services may use tracking technologies to independently collect information about you and may solicit information from you. The information collected and stored by third parties, whether through the Services, a Third-Party Service, a Third-Party Feature (defined below), or a third-party device, remains subject to their own policies and practices, including what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with and consult their privacy policies and terms of service. Third Party Features We may allow you to connect the Services to a Third-Party Service or offer the Services through a Third-Party Service (“Third-Party Features”). If you use a Third-Party Feature, both we and the applicable third party may have access to and use information associated with your use of the Third-Party Feature, and you should carefully review the third party’s privacy policy and terms of service. Some examples of Third-Party Features include the following: <ul> <li> Brand Pages and Chatbots. We may offer our content on social networks such as a Facebook and Twitter. Any information you provide to us when you engage with our content (such as through our brand page or via our chatbot on Facebook Messenger) is treated in accordance with this Privacy Policy. Also, if you publicly reference the Cinnamon Services on a Third-Party Service (e.g., by using a hashtag associated with Cinnamon in a tweet or post), we may use your reference on or in connection with the Cinnamon Services. </li> <li> Platform Linking. We may offer you the ability to link your Cinnamon account to a Third-Party Service in order to retrieve certain data about your account on that service. For example, if you link your Cinnamon account to a gaming platform such as Steam or Twitch, the linking may allow us to obtain information such as your gaming username, email address, photo, game performance, and high scores. For more information about how these platforms handle your information, please refer to their respective privacy policies and terms of service. </li> </ul> CHILDREN Our Service does not address anyone under the age of 13 in the United States of America (“Child” or “Children”). We do not knowingly collect the Personal Information of Children. By using our Services you agree that you are not a Child. If you are a parent or guardian and you are aware that your Child has provided us with Personal Information, please contact us at compliance@cinnamon.video. If we learn that we have collected Personal Information from a Child, we will take steps to delete the information as soon as possible. PROCESSING AND STORING YOUR DATA We regularly review this Privacy Policy and make sure that we process your information in ways that comply with it. To provide our Services, we share information both internally within the Cinnamon companies and externally with our partners, and with those you connect and share with around the world in accordance with this policy. Your information may, for example, be transferred or transmitted to, or stored and processed in the United States or other countries outside of where you live for the purposes as described in this policy. These data transfers are necessary to provide our Services to you. Data protection laws vary among countries, with some providing more protection than others. Regardless of where your information is processed, we apply the same protections described in this policy. Where we transfer your Personal Information outside of the European Economic Area, we utilize European Commission’s model contracts for the transfer of Personal Information to third countries (i.e. standard contractual clauses) pursuant to Commission Decision 2004/915/EC or 2010/87/EU (as appropriate) or in line with any replacement mechanism approved under EU law, and obtain your consent for these data transfers to the United States and other countries. When we receive formal written complaints, we respond by contacting the person who made the complaint. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of your data that we cannot resolve with you directly. Notwithstanding the foregoing, the data collected by us though the emotion detection function of our Services is not transferred to any of our servers or third-party servers used by us, and processing of such data takes place on the User’s device itself. SECURITY The security of your information is a serious issue for us and we are committed to protect the information we receive from you. We use reasonable security measures to protect against the loss, misuse and alteration of your personal information under our control. and to ensure that your information is treated in accordance with this Privacy Policy. Notwithstanding such measures, please be aware that no security measures are perfect or impenetrable, and we cannot guarantee the security of any information transmitted to or from the Services, including your personal information or financial account information. We also are not responsible for the actions of any third parties that may receive any such information. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW WE ASSUME NO LIABILITY OR RESPONSIBILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO ERRORS IN TRANSMISSION, UNAUTHORIZED THIRD-PARTY ACCESS, OR OTHER CAUSES BEYOND OUR CONTROL. BY USING THE SERVICES OR PROVIDING PERSONAL INFORMATION TO US, YOU AGREE THAT WE MAY COMMUNICATE WITH YOU ELECTRONICALLY REGARDING SECURITY, PRIVACY, AND ADMINISTRATIVE ISSUES RELATING TO YOUR USE OF THE SERVICES. IF WE LEARN OF A SECURITY SYSTEM’S BREACH, WE MAY ATTEMPT TO NOTIFY YOU ELECTRONICALLY BY POSTING A NOTICE ON THE SERVICES, BY MAIL OR BY SENDING AN E-MAIL TO YOU. You play an important role in keeping your personal information secure and you should not share your username, password, or other security information for your account with anyone. If we receive instructions using your username and password, we will consider that you have authorized the instructions. If you believe there has been any unauthorized access or use of your information, please contact us immediately atcompliance@cinnamon.video. COMPLIANCE WITH CALIFORNIA LAW The CCPA requires specific disclosures for California residents. Categories of Personal Information we collect <ul> <li> Identifiers, such as your name, alias, address, phone numbers, or IP address; </li> <li> Personal information as described in subdivision (e) of Section 1798.80 of the California Civil Code, such as User wallet details; </li> <li> Demographic information, such as age, language or gender; </li> <li> Commercial information, such as subscription and monetization activities; </li> <li> Internet or other electronic network activity information, including Content interaction information, such as Content downloads, streams, playback details and activity on third-party sites and apps that use our services; </li> <li> Biometric information, such as your voice or appearance, for example if you choose to interact with our live stream features when available; </li> <li> geolocation data, such as the location of your device or computer, for example if you enable location services to enable us comply with applicable laws; </li> <li> audio, visual, electronic or other similar information, including when you use audio features; </li> <li> professional or employment-related information, for example data you may provide to us. and </li> <li> inference data, such as information about your Content preferences. </li> </ul> Categories of Personal Information transferred to third parties <ul> <li> Identifiers, such as your name, address, or phone numbers, for example if we use a third-party service provider carrier to provide our Services; </li> <li> Personal Information as described in subdivision (e) of Section 1798.80 of the California Civil Code, such as a User wallet details, for example if we use a third-party payment processor; </li> <li> Demographic information such as your age, gender, or language, for example if we conduct user surveys or analysis using a third-party service provider; </li> <li> commercial information, such as the details of subscription and monetization activities if a third-party service provider is assisting to provide that the monetization Service to you; </li> <li> Internet or other electronic network activity information, such as if we use a third-party service provider to help us gather reports for analyzing the condition of our devices and Services; </li> <li> biometric information, for example if you choose to participate in a demonstration of certain Services facilitated by a third-party service provider; </li> <li> geolocation data, for example if we enable geo-blocking Services from a third party in connection with our Services; </li> <li> audio, visual, electronic or other similar information, for example if a third-party service provider reviews Content for compliance with Terms of Service or quality assurance purposes. and </li> <li> professional or employment-related information, for example if we provide information to a third-party service provider for verification or registration as part of the our Services; </li> </ul> Business Purpose for which information may be used or disclosed <ul> <li> Protecting against security threats, abuse, and illegal activity. Cinnamon uses and may disclose information to detect, prevent and respond to security incidents, and for protecting against other malicious, deceptive, fraudulent, or illegal activity. For example, to protect our services, Cinnamon may receive or disclose information about IP addresses that malicious actors have compromised. </li> <li> Maintaining our services. Cinnamon uses information to ensure our services are working as intended, such as tracking outages or troubleshooting bugs and other issues that you report to us. </li> <li> Auditing and measurement. Cinnamon uses information for analytics and measurement to understand how our Services are used, as well as to fulfill obligations to our partners like publishers, advertisers, developers, or rights holders. We may disclose non-personally identifiable information publicly and with these partners, including for auditing purposes. </li> <li> Research and development. Cinnamon uses information to improve our services and to develop new products, features and technologies that benefit our users and the public. </li> <li> Use of service providers. Cinnamon shares information with service providers to perform services on our behalf, in compliance with our Privacy Policy and other appropriate confidentiality and security measures. </li> <li> Legal reasons. Cinnamon also uses information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement. </li> </ul> Your Rights You may have the right under the California Consumer Privacy Act to request information about the collection of your Personal Information by us, or access to or deletion of your Personal Information. If you wish to do any of these things, you may submit a request to us at the address in the section entitled “Contact Us” below. We will respond to your request consistent with applicable law and subject to proper verification. And we do not discriminate based on the exercise of any privacy rights that you might have. Cinnamon may share personal information as defined by California’s “Shine the Light” law with third parties and/or affiliates for such third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please contact us as set forth in the section entitled “Contact Us” below. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that Cinnamon is not required to respond to requests made by means other than through the provided email address or mail address. Users who are California residents and are under 18 years of age may request and obtain removal of Content or information they posted on our Services by sending an email to the email address set forth in the section entitled “Contact Us” below. All requests must be labeled “California Removal Request” on the email subject line. All requests must state that the User personally posted such content and provide a description of the Content or information User wants removed and information reasonably sufficient to permit us to locate such Content or information. We do not accept California Removal Requests via postal mail, telephone, or facsimile. We are not responsible for notices that are not labeled or sent properly, and we may not be able to respond if you do not provide adequate information. Please note that your request does not ensure complete or comprehensive removal of the material. For example, materials that you have posted may be republished or reposted by another user or third party. Non-Discrimination We will not discriminate against you for exercising any of your rights under the CCPA. Unless permitted by the CCPA or other applicable law, we will not for the reason of your exercise of rights under the CCPA: <ul> <li> Deny you our Services. </li> <li> Charge you different prices or rates for our Services, including through granting discounts or other benefits, or imposing penalties. </li> <li> Provide you a different level or quality of Services. </li> <li> Suggest that you may receive a different price or rate for Services or a different level or quality of Services. </li> </ul> However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. YOUR EUROPEAN PRIVACY RIGHTS Where the General Data Protection Regulation (the “GDPR”) applies and in accordance with any other applicable law, in certain circumstances and subject to data processing agreements, you have rights in relation to the personal information we hold about you. We set out below an outline of those rights and how to exercise those rights. Please note that we will require you to verify your identity before responding to any requests to exercise your rights by providing details only known to the account holder. To exercise any of your rights, please contact us atcompliance@cinnamon.video. Please note that for each of the rights below we may have valid legal reasons to refuse your request, in such instances we will let you know if that is the case. Access You have the right to know whether we process personal information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with. In order to obtain information and access to data held by you, please contact us atcompliance@cinnamon.video. Portability You have the right to receive a subset of the personal information you provide us if we process it on the legal bases of our contract with you or with your consent in a structured, commonly used and machine-readable format and a right to request that we transfer such personal information to another party. If you wish for us to transfer the personal information to another party, please ensure you detail that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the personal information or its processing once received by the third party. Correction You have the right to require us to correct any personal information held about you that is inaccurate and have incomplete data completed. Where you request correction, please explain in detail why you believe the personal information we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required. Please note that while we assess whether the personal information we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below. Erasure You may request that we erase the personal information we hold about you in the following circumstances: <ul> <li> where you believe it is no longer necessary for us to hold the personal information; </li> <li> we are processing it on the basis of your consent and you wish to withdraw your consent; </li> <li> we are processing your data on the basis of our legitimate interest and you object to such processing; </li> <li> you no longer wish us to use your data to send you marketing. or </li> <li> you believe we are unlawfully processing your data. </li> </ul> Restriction of Processing to Storage Only You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in the following circumstances: <ul> <li> You believe the personal information is not accurate for the period it takes for us to verify whether the data is accurate; </li> <li> We wish to erase the personal information but you want us to simply restrict the use of that data; </li> <li> We no longer need the personal information for the purposes of the processing but you require us to retain the data for the establishment, exercise or defense of legal claims. or </li> <li> You have objected to us processing personal information we hold about you on the basis of our legitimate interest and you wish us to stop processing the personal information while we determine whether there is an overriding interest in us retaining such personal information. </li> </ul> Objection You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. You also have the right, at any time, to object to our processing of data about you in order to send you marketing, including where we build profiles for such purposes and we will stop processing the data for that purpose. Withdrawal of Consent Where you have provided your consent to us processing your personal data, you can withdraw your consent at any time by emailing us atcompliance@cinnamon.video. For the purposes of the Data Protection Act 2018, the General Data Protection Regulation (EU) 2016/679 and any successor legislation to any of the foregoing (together, “Data Protection Laws”), you consent to the holding, disclosing and processing of “Personal Data” and “Special Category Personal Data” (as such terms are defined in the Data Protection Laws) as necessary for Cinnamon to have the rights set forth in this Privacy Policy. CHANGES TO THIS POLICY We change this Privacy Policy from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We always indicate the date the last changes were published and we offer access to archived versions for your review. Any changes will be effective immediately upon posting of the revised Privacy Policy. Your continued use of the Services indicates your consent to the Privacy Policy then posted. If changes are significant, we’ll provide a more prominent notice (including, for certain services, email notification of Privacy Policy changes). CONTACT US If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us: By email: compliance@cinnamon.video By mail: Compliance Officer Cinnamon Technologies, Inc. 8 The Green STE 4000 Dover, DE 19901 USA