Last Updated: July 31, 2021
1. Scope of this Policy
VDMS provides the following business-to-business (“B2B”) services to Customers (defined below): video streaming, content delivery network (“CDN”) services, security and other B2B services (collectively, the “Services”). This Policy applies to VDMS’s collection, use, and disclosure of personal information in connection with the Services. Below are a few definitions used within this Policy:
2. Information We Collect
a. Customers. We collect the following information from Customers:
b. Business Contact Information. As an incident of providing the Services to our Customers, VDMS processes certain Business Contact Information. These business relationships, the personal information processed as a result, and the processing activities of the personal information, are dependent upon the Services and, where applicable, are further defined in the applicable agreements between VDMS and the Customer. In addition, if you (or the company you represent) provide services to VDMS, we may collect your Business Contact information. VDMS may be a controller or processor of this personal information, as set forth in the applicable agreement.
c. End Users. As an incident of providing Services to our Customers, VDMS processes certain personal information from End Users. The End User personal information that may be processed in connection with the Services is set forth in detail in the agreement between VDMS and the Customer, and may vary from Customer to Customer, depending on the Services provided. For example, VDMS collects End Users’ IP addresses to provide the CDN services. VDMS acts as a processor or service provider for all End User personal information that VDMS may process as a result of providing the Services, and follows the instructions of the Customer as set forth in the applicable agreement between VDMS and the Customer.
3. How We Use Personal Information
VDMS uses the personal information described in this Policy to:
4. How We Share Personal Information
a. We may share information with the following categories of recipients:
b. Legal and Other Purposes. We may access, preserve and disclose information to investigate, prevent, or take action in connection with: (i) legal process and legal requests; (ii) enforcement of the terms of the applicable agreement; (iii) claims that any content violates the rights of third-parties; (iv) requests for Customer support services; (v) technical issues; (vi) protecting the rights, property or personal safety of VDMS, its users or the public; (vii) establishing or exercising our legal rights or defending against legal claims; or (viii) as otherwise required by law. This may include responding to lawful governmental requests.
c. New Ownership. If the ownership or control of all or part of VDMS, or a specific Service, changes as a result of a merger, acquisition, sale of assets, or other legal mechanism, we may transfer your information to the new owner or controlling entity.
5. Data Subject Rights
The Services provide various controls to manage certain aspects of your VDMS B2B account. If you would like to exercise certain data subject rights regarding your VDMS B2B account, such as account erasure, please contact your VDMS account representative. If you are a European Economic Area resident and you wish to contact our Data Protection Officer, you can do so via email at email@example.com. Please note, the platform that Yahoo provides to its consumers to manage and control their use of personal information does not work for VDMS B2B accounts. This is because VDMS is a processor for personal information we process on behalf of our Customers
6. Information Security
VDMS has implemented and maintains appropriate technical and organizational measures to protect personal information against accidental or unlawful destruction; or accidental loss, alteration, unauthorized disclosure; or access and against other unlawful forms of processing. You may view such technical and organizational measures at https://www.verizondigitalmedia.com/technology/security-compliance/. VDMS may update or modify such technical and organizational measures from time to time.
7. Data Retention
We generally store personal information for as long as necessary to deliver our Services and for security purposes.
a. In some cases, we store information for longer periods of time, for example, when we need to comply with legal obligations or replicate or back up certain data to “offline” storage for disaster recovery purposes.
b. In addition, we may maintain de-identified data for varying periods for research, reporting and product testing or development.
8. Our Legal Bases for Processing Information.
We mainly rely on three separate bases to lawfully process your information. First, we need to process your information in certain ways to perform a contract with you. Second, where you have given us consent to use your personal information in certain ways (for example, VDMS marketing messages about new services), we will rely on your consent. Third, in certain cases, we may process your information where necessary for the purposes of our legitimate interests or the legitimate interests of third parties, where those legitimate interests are not overridden by your rights or interests. Occasionally, VDMS may rely on other legal bases to process your information, such as to protect a user’s vital interests (such as where there is a risk of imminent harm) or to comply with a legal obligation.
9. Data Processing and Transfers
a. VDMS processes Customer information related to individuals in the EU/EEA/UK and transfers that information from the EU/EEA/UK through various compliance mechanisms, including data processing agreements based on the European Commission’s Standard Contractual Clauses, in accordance with the agreement between Customer and VDMS.
b. The United States and other non-EU/EEA/UK countries have different laws on data protection and rules in relation to government access to information. If you are based in the EU/EEA/UK, when your data is moved from your home country to a third country outside the EU/EEA/UK, some of these countries may not have the same data protection safeguards as your home country.
c. If you have questions about data transfers, please use one of the points of contact listed in section 12 of this Policy.
10. Other Important Information
This Policy applies only to VDMS and not to other Yahoo brands or companies. This Policy does not apply to the practices of companies that VDMS does not own or control, or to people that VDMS does not employ or manage.
We may update this Policy from time to time, so you should check it periodically.
12. Questions & Suggestions
If you have questions, suggestions, or wish to make a complaint, you may reach out directly to your VDMS account representative, or contact us at:
Address: VDMS13031 West Jefferson Boulevard, Building 900
If you wish to contact our Data Protection Officer, you can do so by post to: Attn: Data Protection Officer, Verizon Media EMEA, 5-7 Point Square, North Wall Quay, Dublin 1, Ireland.
Our Article 27 Representative can be contacted by email at GDPRrepresentative@mhc.ie, or by post at:
MHC GDPR Representative
Mason Hayes and Curran Professional Services Limited
South Bank HouseBarrow Street
Tel: +353 1 614 5000