VIO, INC. PRIVACY POLICY
Last Updated September 26 2016

We at Vio, Inc. (“Dubsat,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy relates to the information collection and use practices of Dubsat in connection with our online services, which are made available to you through a variety of platforms, including, but not limited to, WWW.DUBSAT.COM (the “Website”).

Description of Users and Acceptance of Terms

This Privacy Policy applies to visitors to the Website, who view only publicly-available content (“Visitors”) and subscriber (“Subscribers”) who have signed up to access and use our services (the “Services”).

By visiting our Website, Visitors are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

By signing up, accessing, and/or using our Services, each Subscriber is agreeing to the terms of this Privacy Policy and the accompanying Subscription and Services Agreement.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Use (when such term concerns Visitors) or the Subscription and Services Agreement (when such term concerns Subscribers).

The Information We Collect and/or Receive; The Purpose of Collection and Use

In the course of operating the Website and performing the Services, Dubsat will collect (and/or receive) the following types of information. You authorize us to collect and/or receive such information.

1. Contact Information

When you contact us via the Contact Us page, or sign up to become a Subscriber, you will be asked to provide us with certain information which may include your name, address, phone number, and e-mail address (“Contact Information”). The Contact Information is used to provide the requested Services or information, and to contact Subscribers and Visitors for purposes of direct marketing of our current and future Services.

2. Billing Information.

When Subscribers sign up with us, they may be required to provide certain information in addition to the Contact Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information (“Billing Information”). Billing Information is collected and processed by our third-party payment processor acting as our agent (See, Onward Transfers to Third Parties). We do not directly obtain or process any Billing Information.

3. Data.

In using the Platform, Subscribers may provide us Data (as defined in the Subscription and Services Agreement). We use the Data in accordance with the terms and conditions of the Subscription and Services Agreement.

4. Other Information.

In addition to the Contact Information, and the Data, we may collect or receive additional information (collectively, the “Other Information”). Such Other Information may include:

a. From Your Activity In an ongoing effort to improve the Website, the Platform and the Services, we automatically collect certain information when Visitors visit the Website and when Subscribers use the Services. This information consists of IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; Browser type and language; Referring and exit pages and URLs; Date and time; Platform usage, such as the amount of time spent on particular pages and other performance and usage data; and similar data concerning your use of the Website and the Services.

b. From Cookies

We also collect Activity Information by using “cookie” technology. Cookies are small packets of data that a website stores on the hard drive of your computer or mobile device to “remember” information about your visit. We may use both session cookies, which expire once you close your web browser, and persistent cookies, which stay on your computer until you delete them and other technologies to help us collect Other Information and to enhance your experience using the Website and/or the Platform. Our cookie policy is available at www.dubsat.com/cookie-policy. If you do not want us to deploy cookies in your browser, you can opt out by setting your browser to reject cookies or to notify you when a website tries to put a cookie in your browser software. If you choose to disable cookies in your browser, you can still use the Website and the Platform, although your ability to use some of the features may be affected.

c. Third-Party Analytics

Like most organizations, we rely on automatic data collection technology (Google Analytics) when you visit our Website or use the Platform. Google Analytics may use tracking technologies such as but not limited to cookies to collect information on our behalf such as your IP address, Internet service provider, browser type, operating system and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and other data. By accessing and using the Website and/or the Platform, you consent to the processing of data about you by Google Analytics in the manner and for the purposes set out in this Privacy Policy. For more information on Google Analytics, including how to opt out from certain data collection, please visit https://www.google.com/analytics. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Website or the Platform.

d. From You

We receive additional information that Visitors and Subscribers voluntarily provide to us. Such information may include product and service preferences, and other information that does not identify them personally.

Aggregate Data

In an ongoing effort to better understand our Visitors and Subscribers and the products and services of Dubsat and our promotional partners, we may analyze your information in anonymized and aggregate form in order to operate, maintain, manage, and improve the Website, the Platform, and/or such products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, business and promotional partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Website, the Platform, and these products and services to current and prospective business partners and to other third parties for other lawful purposes.

Additional Uses

We also use Contact Information, and other information collected pursuant to this Privacy Policy to respond to general inquiries, solicit feedback regarding our Website, Platform and the Services, provide support, provide relevant content on our Website, and to communicate with you via email regarding our current and future Services.

Onward Transfer to Third Parties

Like many businesses, we hire other companies to perform certain business-related services. We may disclose personal information to certain types of third party companies but only to the extent needed to enable them to provide such services. The types of companies that may receive personal information and their functions are: data storage, hosting services, customer service, support and technical assistance, sales and customer relationship management, and payment processors. All such third parties function as our agents, performing services at our instruction and on our behalf pursuant to contracts which require they provide at least the same level of privacy protection as is required by this privacy policy and implemented by Dubsat. We may also disclose your personal information to our parent companies, subsidiaries, joint ventures, affiliates, or other companies under common control with us, including, without limitation, Vio Worldwide Limited, Dubsat Pty Limited, Dubsat NZ Limited, Ambience Entertainment Pty, Ambience Concept Pty Limited, Omnilab Media Melbourne Pty Limited, and Omnilab Media Pty Limited in order to support marketing, sale and delivery of Services. You may opt out of having your personal information transferred to any or all of our categories of agents by contacting us at PRIVACY@DUBSAT.COM . Please allow us a reasonable time to process your request. With regard to the Principle of Accountability for Onward Transfer, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.

We may transfer your personal information to third parties that will determine the purpose and means of processing your personal information (referred to as “controllers”) for the limited and specified purposes described herein and for which you have granted your consent. The types of such third parties that may receive your personal information are: Dubsat Subscribers (which may be publishers, or broadcasters), and to whom you granted consent for the collection and processing of your personal information in accordance with this privacy policy. You may opt out of having your personal information transferred to any or all of these third party controllers by contacting us at PRIVACY@DUBSAT.COM.

Opt-In to Certain Onward Transfers

We will not transfer your personal information to third parties acting as controllers who may use your personal information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you without first providing you with information regarding the identity of such controller or the nature of such controller’s business, and obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent.

We will not disclose your sensitive personal information to any third party without first obtaining your opt-in consent. When we provide this information regarding requested disclosure, we will include instructions for how to grant consent.

In each instance, please allow us a reasonable time to process your response.

Business Transfers

In the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this privacy policy. This policy shall be binding upon Dubsat and its legal successors in interest.

Disclosure to Public Authorities

We may be required to disclose personal information in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements. We may also disclose personal information to other third parties when compelled to do so by government authorities or required by law or regulation including, but not limited to, in response to court orders and subpoenas.

Opt-Out for Direct Marketing

You may opt out at any time from the use of your personal information for direct marketing purposes by emailing the instructions to this email address: PRIVACY@DUBSAT.COM. Please allow us a reasonable time to process your request.

Access to personal information

Dubsat acknowledges that EU individuals have the right to access the personal information that we maintain about them. Upon request to PRIVACY@DUBSAT.COM, we will provide you with confirmation as to whether we are processing your personal information, and have the data communicated to you within a reasonable time. You have the right to correct, amend or delete your personal information where it is inaccurate or has been processed in violation of this privacy policy. We may require payment of a non-excessive fee to defray our expenses in this regard. Please allow us a reasonable time to respond to your inquiries and requests.

Retention of personal information

We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. After such time periods have expired, we may either delete your personal information or retain it in a form such that it does not identify you personally.

Accessing and Modifying Communication Preferences

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Dubsat marketing e-mail. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Subscribers cannot opt out of receiving transactional e-mails related to their account with Dubsat.

How We Protect the Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

External Websites

The Website may contain links to third-party websites. Dubsat has no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Children

We do not knowingly collect personal information from children under the age of 13 through the Website or the Platform. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information without their permission. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Important Notice to All Non-US Residents

Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. Except in the case of data transfers under the EU-US Privacy Shield and the U.S.-Swiss Safe Harbor Framework, your decision to provide such data to us, or allow us to collect such data through our Website or the Services, constitutes your consent to this data transfer.

Important Notice For Residents of the European Economic Area

Dubsat complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from the European Union member countries (including Iceland, Liechtenstein and Norway). Dubsat has certified that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability (the “Privacy Shield Principles”). If there is a conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Dubsat is subject to the investigatory and enforcement powers of the Federal Trade Commission.

In compliance with the EU-US Privacy Shield Principles, Dubsat commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Privacy Policy should first contact Dubsat at PRIVACY@DUBSAT.COM. Dubsat has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Dubsat, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. If these processes do not result in a resolution, you may also contact your local data protection authority, the US Department of Commerce, and/or the Federal Trade Commission for assistance. Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Important Notice for Residents of Switzerland

Dubsat complies with the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Dubsat has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access and enforcement. If there is any conflict between the policies in this Privacy Policy and the Safe Harbor Privacy Principles, the Safe Harbor Privacy Principles shall govern.  To learn more about the US-Swiss Safe Harbor and to view our certification page, please visit http://www.export.gov/safeharbor/.

In compliance with the US-Swiss Safe Harbor Principles, Dubsat commits to resolve complaints about your privacy and our collection or use of your personal information.  Swiss citizens with inquiries or complaints regarding this Privacy Policy should first contact Dubsat at PRIVACY@DUBSAT.COM.

Dubsat has further committed to refer unresolved privacy complaints under the US-Swiss Safe Harbor to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

California and European Union Residents

Under California Civil Code Section 1798.83, California residents who have an established business relationship with Dubsat may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to PRIVACY@DUBSAT.COM with “Privacy Policy” in the subject line or write to us at:

Vio, Inc.

307 Seventh Avenue

Suite 1803

New York, New York 10001

In addition, Dubsat does not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

If you are a resident of the European Union, you are entitled to withdraw consents to marketing contact at any time. To exercise this right, please send us an e-mail or letter to the contact points above.

Changes to This Privacy Policy

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the Website. By accessing the Website or the Platform and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please contact Dubsat via e-mail at PRIVACY@DUBSAT.COM with “Privacy Policy” in the subject line.