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Welcome to our Privacy Policy!

Last modified: February 2024

Oranum Broadcaster is an entertainment site and application, offering informative, interactive and entertaining content such as stories, highlights, images and videos.

When you decide to register as a Broadcaster or under an Agency, and provide online entertainment performances (hereinafter, the “Performance”, as defined in our Terms and Conditions), we will collect some of your personal data. Please be assured that we are fully dedicated to the protection of your personal information.

We operate our site/app and our services in compliance with applicable data protection laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”). For more information, please see Section 7 “YOUR RIGHTS UNDER GDPR”. If you are a California resident, please also see Section 8 “INFORMATION FOR CALIFORNIA RESIDENTS.”

Your privacy is important to us. We provide you with this Privacy Policy, so that you can make informed choices about the use of your data. This Privacy Policy describes how we collect, use, share, and store the personal data of individuals who register as Broadcasters (”Broadcasters”). Please note that this Privacy Policy only applies to the personal data of Broadcaster. Personal data of guests (“Guests”) and members who subscribe Oranum.com (“Members”) is governed by a separate Privacy Policy.

As used in this Privacy Policy, the term “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. For example, under CCPA Personal Data includes identifiers such as your real name, alias, or postal address; commercial information, including records, products or services purchased; Internet or other electronic network activity information, including, but not limited to, browsing history, and search history; and audio or video recordings. CCPA § 1798.140(o)(1).

Please read this Privacy Policy carefully. This Privacy Policy forms a part of and is incorporated into the Oranum Broadcaster Terms and Conditions. By using Oranum Broadcaster you agree that the Terms and Conditions, including this Privacy Policy, forms a binding legal contract with you.

You can contact us if you have any questions about our privacy practices or about what we are doing with your personal data. We will be happy to assist you in any way we can.

1. WHO DECIDES “HOW” AND “WHY” YOUR PERSONAL DATA IS PROCESSED?

The following companies decide how and why your personal data is processed, and for GDPR purposes, are “Joint Controllers”:

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249539.


JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Registered with the Luxembourg Trade and Companies Register under the number: B 249566.


JWS Americas S.à r.l. and JWS International S.à r.l. jointly determine the purposes and means of the processing of your personal data. Both entities collaborate in joint processing activities related to the purposes mentioned in this Privacy Policy.

We have put in place a joint controllership agreement (according to article 26 GDPR) in order to determine the respective roles and responsibilities of the Joint Controllers, in particular, as regards the exercise of data subjects’ rights and the duties to provide information. You can notably contact us through a single contact point as mentioned in Section 10 of this Privacy Policy.

Please note that, irrespective of this arrangement, you are free to exercise your rights (as described in the Privacy Policy) in respect of and against each of the Joint Controllers. You also have the right to contact us and request to be informed about how the responsibilities are allocated between the two companies.

2. WHAT PERSONAL DATA DO WE PROCESS?

We collect, use, share, transfer, and store different types of personal data as a result of your registration and Performance on our site/app.

There are two possibilities for you to create an account:

  • Broadcaster Account

This means that you register directly and individually as a Broadcaster.

  • Agency Account

You can register an Agency Account under which you can create several Broadcaster Accounts. Please note that these will be associated with the primary Agency Account.

If you are the Broadcaster of the account, and therefore named Agency, you can either be:

  • A Broadcaster yourself and open a Broadcaster account under your Agency account
  • A person (natural or legal) having contracted with Broadcasters and opening an Agency account to enable them to provide their Performance on the site/app

This Privacy Policy will apply to you regardless of what kind of account you decide to create/register.

The personal data we collect include the following categories of data:

2.1. Personal Data You Provide

Please note that if your account has been created as part of an Agency, the Agency will provide us with some, or all the information indicated below. 

  • Broadcaster Account

When you create a Broadcaster Account, we require the following details about you:

  • Email address
  • Password
  • Your identification information, that is to say your full name, date of birth, gender, country and nationality. We will also request that you upload an official document, such as your ID card, passport or driving license, for identity verification purpose;
  • Screen name
  • Display name

We will request that you upload an official document (e.g. ID card, passport, driving license), together with a selfie of you, for identity verification purposes or compliance with audit checks.

Once your account has been created, you can choose to add any information about you, upload pictures and videos, add story and highlights, etc.

Please also be aware that any content you provide is subject to intellectual property protection. Read the Terms and Conditions for the specifics of how you are affected.

  • Agency Account

When you create an Agency Account on our site, we may require the following details about you:

  • Email address
  • Password
  • ID information provided through ID card, passport or driving license for identification licenses

This includes the following (if you are an individual):

  • Full name
  • Date of Birth
  • Country
  • Nationality

Or, the following (if you are a legal entity):

  • Agency legal business name (i.e. company name)
  • Country, city, ZIP, address
  • Registration number of the company
  • VAT number

If you are a legal entity, we may collect the following information about your legal representative:

  • Full name
  • ID number
  • Date of Birth
  • Country, city, address, ZIP

We will also request that you upload an official document (e.g. ID card, passport, driving license) for identity verification purposes or compliance with audit checks.

Once your account has been created, you can choose to do add any further information about yourself.

Please also be aware that any content you provide to the site is subject to intellectual property protection. Read the Terms and Conditions for the specifics of how you are affected.

  • Billing Support & Broadcaster Support

We collect all information you choose to share with our Billing Support & Broadcaster Support teams, including:

  • Your personal email
  • The subject of your request and the Members or other Broadcasters associated
  • Your comments or opinions about a Member or another Broadcaster
  • Your conversations with the relevant team

More generally, when you communicate with us in any other way, we will collect whatever information you provide us with.

  • Pay-Out Page

When you complete the Pay-Out Page to receive payment of your earnings, we will collect any information you provide via that page, including:

  • Your billing address, including city, ZIP, address
  • Payment method (i.e. virtual account, wire transfer)

This will affect what other information we collect, including if you have to provide the following:

  • Account information
  • Other ID/Payment information
  • ID Details
  • Address of beneficiary (if applicable)

If you are a company, we will ask you to provide the identification details of the managing director or representative of your company.

Please note that, if you choose to receive money through a virtual account, we will not be responsible for the data you provide to the third party who creates and manages your virtual account. Please ensure that you check the privacy policy of the virtual account provider if you want to learn more.

Depending on your payout method, your payout will be processed by affiliates of our group or third parties payout processors/service providers as explained in Section 6.5. “Payment providers and financial institutions. 

If you wish to change your pay-out details, you can do so at any time by sending an email to payinfo@oranum.com from your registered email address and providing us with the following minimum documents:

  • Scanned copy of your photo ID
  • Photo of you holding your ID next to your face


2.2. Personal Information from Site Use

We collect and process certain information about you when you navigate the site or use the app and provide your Performance.

This means that, when you browse the site, use the app, or take any other action, we collect certain information, including:

  • Usage Information

We collect information about your activity and about how you interact with the features of the site or the app, including:

  • Activity history
  • Special features used, e.g. uploading content

We collect information about how you communicate with Members, including:

  • Time & date of communication
  • Time spent online
  • Method of communication (e.g. Messenger)
  • Content Information

We collect any content you share including the following:

  • Images, text or videos you upload
  • Messages sent or received
  • Information about the content you create/provide

Your live stream may also be recorded and kept for a maximum period of one month for quality check purpose.

Please be aware that any information you make public (e.g., profile picture) will be visible and may appear in search engine results. Please note that you can upload at least 6 (six) stories a time up to 50 or more, and they will be all visible to both Guests of the website and Members and until you decide to publish a further one. In this case, the first story you published will not be shown anymore in your profile in order to make space to the new one. Please note that the number of stories, images, text or videos you may upload in your last 50 or more stories will be always visible unless you decide to delete them voluntarily. Please note that the number of stories available might be updated from time to time due to the feature implementations and when you will reach the limit of uploads you will be notified that your first story will be deleted.

Please also be aware that our Support Team might decide to put one of your stories as a highlight accessible by the Guests of the website from the homepage.

All Guests visiting the website can see your profile picture, your bio, the number of your followers and the content you decided to make public. The Members will be able to send you messages, surprises, video call and audio call you.

Please also be aware that we collect all communication data between yourself and our company, including but not limited to, telephone conversations, chat logs, text messages, faxes and letters.

  • Earnings

We calculate your earnings by given period based on the following:

  • Your activity
  • Amount paid by Members
  • Time spent online in given period
  • Your participation to the referral program (further explained in the Terms and Conditions)

You can access the details of your earnings via your account settings in the pay-out section. However, please note that this differs depending on how your account was created:

  • Individual Broadcaster Account

You can access this information within your account settings, as described above.

  • Agency-affiliated Broadcaster Account

Whether you can see your earnings, will depend on whether your Agency has decided to share this information with you.

  • Agency Account

You can see the earnings of all Broadcasters under your Agency and choose whether they (the Broadcasters) will be able to see their individual earnings, or not.

Please note that when you are referred by one of our Broadcasters, based on the referral program terms, your referrer will be able to calculate your earnings for all the duration of the program.

  • Log Data & Device Information

We automatically collect log data and information from/about your computer, phone or other device you use to access or navigate our site or app, including:

  • IP address
  • Date and time you logged in
  • Pages viewed
  • Features used
  • Hardware/Software/Internet browser used
  • Operating System/Application version used
  • Cookies / other technologies that may uniquely identify your device / browser

If you are using a mobile device, we might also collect:

  • Data that identifies your mobile device
  • Device-specific settings & characteristics
  • Location details
  • App crashes & other system activity
  • Cookies / Other technologies

Like many websites and applications, we use cookies and other technologies (e.g., web beacons, web storage, unique advertising identifiers, etc.) to collect information about your activity, browser and device.

We rely on your consent to use these technologies. Please keep in mind that removing or choosing not to accept cookies may negatively affect your use of the services on our site/app.

You can withdraw your consent or modify your cookies settings through the settings of your web browser or device.

To learn more about how we use cookies, and your choices, please check out our Cookie Policy.

Hotjar

Hotjar is a third party technology service that helps us better understand our users (e.g. which pages they spend the most time on, which links they click on, what they do and don’t like, etc.), enabling us to build and maintain our service with user feedback.

Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (e.g. IP address, device screen size, device type, browser information, geographic location (country only), preferred language, etc.). They store this information in a pseudonymized user profile.

Please also note that, for the same purposes mentioned above, we might use Hotjar to propose surveys to you. In this case your personal data related to the survey will be processed if you provide your consent to it.

Neither Hotjar nor we will use this information to identify individual users or to match it with further data on an individual user.

For further details, please see Hotjar’s privacy policy here.

You can opt-out of a user profile on Hotjar and Hotjar’s use of tracking cookies by following this opt-out link.


2.3. Data Collected by Third Parties

The following are situations where your personal data may be collected from a third party:

  • Members

When discussing with our Support teams, Guests, Members or other Broadcasters may provide information about you.

  • Agency registration of Broadcaster Accounts

If you are a Broadcaster and your account was created by a separate organisation/person, then be aware that the Agency will provide us with some or all of the registration details required to create your account as mentioned in clause 2.1: “Personal Data You Provide”.

  • Third Party Partners/Service Providers

These third parties assist us in maintaining data accuracy and providing and enhancing our services.

We also use external partner ad networks, which help us to promote our sites or app. They may collect information about your experiences and interactions with our ads on our behalf.

2.4. Public Personal Data

We collect publicly available information about you only when it is necessary to prevent fraud and illegal activities on our site or app, as well as to perform a general background check on you for know-your-customer (KYC) purposes, in databases containing publicly available information.

This data may comprise publicly available information you share on social media like Facebook, a personal blog and/or site, and any other public data available on the internet.

This information is always associated or combined with the data we collect through our site or app to finalize our investigation before reporting any fraud and/or illegal activity to the authorities. We never use publicly available data for any other purpose.

2.5. Sensitive Personal Information

  • We process the following sensitive information about Broadcasters:

Your philosophical or religious beliefs and data about your philosophical or religious beliefs

Oranum is an entertainment site, and we are processing data about your activity, and possibly about your philosophical or religious interests.

When you register as a Broadcaster on our site or when your Agency registers you on the site, you or the Agency choose the category under which you wish to provide services. Due to the explicit meaning of certain category names, it is possible that the chosen category reflects your philosophical or religious beliefs.

We understand that this may not explicitly reflect information about your life outside of the site. It may only be a punctual interest. However, to provide you with the highest level of data protection, we treat this information as sensitive.

In addition, given the nature of our site, and depending on what you decide to show publicly and/or only to the Members, we may have content related to your philosophical or religious interests (uploaded content, stored live cam performances, or private chats with Members) about you.

  • What are your choices?

We will always ask you to agree to the use of your sensitive data. If your Agency has made your registration and created your account, because we do not have a direct relationship with you at that time, your Agency shall be responsible for asking your consent for the use of your sensitive information beforehand.

Please note that, due to the nature of our site, refusing to provide or revoking your consent to have this data collected and processed by us means that you will not be able to register as a Broadcaster or to log in your account.

3. WHY DO WE PROCESS YOUR PERSONAL DATA?

We use the information we collect for the following purposes:

3.1. Account Activation

  • Required Information

We primarily use the data you give us when creating your account to open and manage this account. The account then allows you to upload content and take actions on the site/app.

Your account will also allow you to exercise control over your personal data. Through your account, you can view your pay-out page and manage your personal settings. You are in control of what you use to complete your profile and can choose the content you wish to share with the Members.

We process this information to perform the contract that we have with you and provide you with the platform you can use to provide your Performance. If you fail to provide the minimum details required, we will not be able to create your account and allow you to use our services.

  • Additional Information & Content

You have the option to provide additional information on your profile. This information and content may be shared with our Guests and/or Members upon certain conditions (e.g., when a Member unlocks paid features, buys premium content, etc.).

We process this information to perform the contract that we have with you and provide you with the platform you can use to provide your Performance.

3.2. Improve and Promote our Services

To understand how we can improve our services and to promote them to others, we collect your personal data for the following purposes:

  • Analytics & Statistics

We use the information you provide us with and that we collect ourselves to measure traffic and detect general trends regarding the preferences/habits of our users. This helps us to generate statistical reports on Broadcasters including indicating earnings per country. The information in these reports is in aggregate form and cannot be used to identify individuals.

  • Feedback

We process the data relating to your activity and income to provide you with feedback on your performance. For example, regarding your earnings.

Please note that we display income statistics and a pay-out overview in the pay-out section of your account.

  • Improvements

We use your data for testing, troubleshooting and improving the functionality and quality of our online entertainment services. Our main goal is to optimize our site/app and services, making them easier and more enjoyable to use.

We also use some of your data (e.g. information on the content created, screen name, your current status, etc.) to improve the search functionality on our site. Indeed, in order to make our services useful for the Guests and Members, the rank and the relevance of the results obtained through the search functionality may be improved based on attributes we determined (e.g. the newest content published by Broadcasters, the live status of Broadcasters, etc.). 

  • Contests, games, events & Awards

We organise contests, games and events occasionally, in order to allow you to increase your visibility and/or your earnings.

As regards the Awards, we will process your total earning on a given period in order to establish your ranking and your total reward amount.

We can also process your time spent online in order to calculate and establish an extra income as further explained in our Terms and Conditions.

In case any other game/contest is organized, we will process your results in order to provide you with the defined reward (e.g. if a quiz is organized, we will process your quiz results in order to provide you with the defined reward).

The ranking of the Broadcasters following the contests, games, Awards may also be published on the site/app.

  • Promotion of the Broadcaster’s activity and of the site

In case your earnings (or the earnings of a Broadcaster of your Agency) are amongst the top earnings in a given month, we may publish such information along with your display name and profile picture, as the case may be.

We process this information with the legitimate interest of developing, improving and promoting our site/app and your Performance as a Broadcaster. 

When we use cookies or similar technologies for the same purpose (i.e. product enhancement/improvement/promotion), we rely on your consent for the use of cookies, including third party cookies.

To learn more about how we use cookies, and your choices, please check out our Cookie Policy.

3.3. Broadcaster/Agency Relationship Management

Broadcaster /Agency management is key to our service. The following are related instances where we collect and process your personal data:

  • Broadcaster Support

Broadcaster Support operates 24/7. By sharing your personal data with our Broadcaster Support team, we will be able to provide you with your answers, and any help you may require, more efficiently.

All your communications with the team and any information you provide, including comments/reviews of Members or another Broadcaster, are stored and reviewed so that we may respond to your request. This way we can ensure the full compliance of all users with our Terms & Conditions and Service Agreement (as applicable).

Some of these communications will be used for training purposes within the Broadcaster Support team, so that we can provide you with an excellent service.

Please be aware that our Broadcaster Support team will have access to all information that has been collected about you (on a need to know basis). By having this access, we ensure that our Support team has everything they need to give you an appropriate and efficient response. This will also allow our Support team to detect any fraudulent activity.

  • General Exchanges

Please note that we may contact you through emails or other appropriate means, to inform you of any changes regarding the site/app or announcements relating to your account (e.g. successful registration).

  • Contests, Courses and training

We organise contests, games and events occasionally, in order to allow you to increase your visibility and/or your earnings. We may use your email address to invite you to participate and inform you of the results.

We may organise courses/training occasionally on different topics, and we may use your email address to invite you to participate. You may also need to create an account on our service provider’s platform in order to access the training/courses.

We have a legitimate interest in improving our users’ experience and delivering appropriate support services to you.

3.4. Payment & Accounting

We use your data for payment and accounting purposes, to process transactions and maintain legally required financial records.

We also use your data, if necessary, to investigate any issues we might encounter with your bank (e.g. bank transfer issues with your account).

The use of your personal data is strictly necessary in this instance in order to execute any payments for the adequate performance of the contract we have between you once you have registered on the site/app.

3.5. Ensure a safe and Trusting Environment

To protect you and our business, we use your personal data in the following ways:

  • To detect and prevent fraud/illegal activities
  • To detect potential breaches to our Terms and Conditions or to the rules of our site or app, as explained in the Terms and Conditions
  • For security & risk assessment (e.g. authentication & verification of identity)

 We have a legitimate interest in keeping you and our business safe and ensuring compliance with the T&Cs/rules, which attempt to guarantee this.

3.6. Marketing/Information Messages

Generally, when you sign up to use our site/app, we will send you informative messages and marketing to keep up to date with the release of new features and/or services.

In terms of informative messages, these will include newsletters and information regarding any workshops or events, which could help you to improve your Performance or develop your activity.

For marketing, these may be tailored to your profile (e.g., country).

We may also send you emails inviting you to participate in surveys so that we can receive feedback on your experiences with our business and/or brand in order to improve them.

We may pseudonymize your email address and use it to generate statistical results. These statistics are in the form of aggregated data and not personal information (e.g. number of registered Broadcasters per country).

We have a legitimate interest in keeping you informed and in the outcome of our marketing campaigns. You can, of course, unsubscribe from receiving these messages at any time by using the link located within the emails themselves. You can also opt-out via the “Consent Settings” in your account or via email to privacy@oranum.com; however, this means that you may miss out on interesting newsletters, workshops, and events, some of which are designed to help you develop your content and activity.  

3.7. Comply with any legal requirements and enforce our legal rights 

We may rely on a legal obligation to process your personal data. For example, we must retain your transaction information to maintain legally required accounting records.

We may also use your information to respond to requests from competent authorities or given our legitimate interest to establish, exercise or defend legal claims. If necessary, we would use your data to investigate issues with the relevant bank processing your payment, or with a debt collector, in cases of unpaid transactions, chargebacks or refunds.

We may also combine your data with information lawfully obtained from other third-party sources, for the above purposes.

4. HOW DO WE PROTECT YOUR PERSONAL DATA?

We implement various security measures, technical and organisational, to ensure the protection of your personal data against unauthorized access, modification, disclosure or deletion.

We periodically test our IT systems, conduct penetration tests and implement data loss prevention systems against leakage, theft and data breach.

Our site incorporates reasonable security technologies in order to ensure the safety of its users and the safekeeping of their related information.

5. HOW LONG DO WE RETAIN YOUR PERSONAL DATA?

We will retain your personal data for as long as we consider it necessary for:

  • Performance of the contract we have with you

To perform the contract we have with you, including maintaining your Broadcaster /Agency account.

  • Legal Obligation Compliance

For example, we may keep some of your information for tax, legal reporting and auditing obligations. Please note that in accordance with Luxembourg legislation, financial information will be kept for a minimum period of 10 years.

  • Legitimate Interests and Business Conduct

Including:

  • Establishing, exercising or defending legal claims
  • Fraud/illegal activity detection and prevention
  • Support training
  • Quality check
  • Enhancing safety

For example, if we suspend or close your account due to fraud or illegal activities, we may retain data about you to prevent you from opening a new account in the future. Such data will also be kept available in case of ongoing judicial proceedings and/or investigations.

  • Security

As we have said, the protection of your information from accidental or malicious loss and destruction is one of our top priorities.

Residual copies of some of your personal information will be kept on our backup systems for 30 days.

Some anonymized copies of your information (e.g. log records) may also remain in our database.

If you have a question about any specific retention periods of certain personal data, please contact us via the contact details provided in Section 10 “HOW TO CONTACT US?”

6. WITH WHOM DO WE SHARE YOUR DATA?

 6.1. Guests

The data you use to complete your Broadcaster profile will be publicly visible to all the Guests and Members visiting the website and/or the app. Please remember that you are in control of what you choose to put in your profile and you may also add or delete optional information about you.

Please also remember that if you choose to be in live stream, your live will appear public and it will be viewed by both Guests and Members navigating in that moment through the website and/or the app. 

6.2. Members

Once a Guest has signed up/logged in, as a Member, it will be possible for him/her to have access to your locked content using purchased coins. Please remember that you are in control of what you choose to put in your profile as a free content or content addressed only to the subscribers of your account. You may also add or delete optional information about you. 

Please be aware that, like Guests, Members will be able to see the live streams and all the content you decided to make public.

Be assured that we will never publish any identification details about you, which would permit to find your real identity (for example, your name and family name, your address, your birthdate, your ID card info, etc…).

6.3. Referrer Broadcaster

When you are referred by one of our Broadcasters, based on the referral program terms, your referrer will be able to calculate your earnings for all the duration of the program.

Be assured that we will never publish any identification details about you, which would permit to find your real identity (for example, your name and family name, your address, your birthdate, your ID card info, etc…).

6.4. Entities of Our Company’s Group

We share your personal information with the following companies of our group based in Luxembourg, Hungary and the US, as they are helping us deliver our services:

  • Jasmin IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Jasmin Holding SA, 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Docler IP S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Jasmin SSC Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
  • Jasmin IP S.à r.l. Hungary Branch, Expo tér 5-7, H-1101, Budapest, Hungary;
  • Docler Services Kft, Expo tér 5-7, H-1101, Budapest, Hungary;
  • Docler LA LLC, 10811 Washington Blvd, Culver City, CA 90232, USA;
  • Escalion S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg;
  • Duodecad IT Services S.à r.l., 44, Avenue John F. Kennedy, L-1855, Luxembourg, Grand Duchy of Luxembourg.

6.5. Service Providers

We use carefully selected and trusted third parties, who act as data processors.

We ensure that they are contractually obligated to process information we share with them in accordance with our instructions, this Privacy Policy, and all applicable data protection laws.

As we constantly work on the development and enhancement of the technology to support our site or app, our third party processors may regularly change.

Such entities mainly operate in the following areas:

  • Business intelligence and analytics
  • Marketing & Sales
  • Customer care
  • Fraud prevention
  • Personal development and training

6.6. Payment Providers & Financial Institutions

For pay-out purposes, we may share certain information with a third party bank or payment processor.

You may receive transactional emails from this party confirming the payment, including dispatch and follow-up invitations to leave feedback for this party.

We may share information with relevant financial institutions, payment processor or any other third party, if we consider it strictly necessary for fraud detection and prevention purposes.

This Privacy Policy does not govern the processing of your personal information by third parties if it was shared directly with them.

6.7. Law Enforcement Agencies & Governmental Authorities

To the extent permitted by applicable laws, we may also share information with law enforcement agencies or authorities, if such disclosure is reasonably necessary for the following:

  • To comply with our legal obligations
  • Respond to information requests for fraud investigations and other alleged illegal activities
  • Enforce and administer our Terms and Conditions & any other applicable policies/contract
  • Protect our rights and defend ourselves against any claims

6.8. Business Transfers

Your information may be transferred to another entity of our group (i.e. as a result of reorganisation, restructuring, etc.) or third party (i.e. as a result of sale, merger and/or acquisition, etc.) if part (more than 50%) or whole of the business (or related assets) is either directly or indirectly transferred or falls under the control of the new owner.

This would be the case providing the new owner operates in the same or similar line of business as ours and commits to comply with this Privacy Policy.

7. YOUR RIGHTS UNDER GDPR

7.1.  Information on the transfer of your personal data outside of the European Economic Area

As we are a Luxembourg-based company, we comply with the EU Data Protection Regulation, “GDPR”. Regardless of whether you are located in Europe or elsewhere, our own location in Europe requires us to comply with GDPR. You can read the entire Regulation here.

During the course of operation and exploitation of the site/app and provision of services, your personal information may be transferred outside of the European Economic Area (“EEA”) to our affiliated companies, or third party data processors, located in the United States and other countries, for the purposes specified in this Privacy Policy.

If we transfer your personal data outside of the EEA, we endeavour to ensure that your rights and freedoms in respect of the processing of your personal data are adequately and appropriately protected. For this purpose, we utilize the Standard Contractual Clauses approved by the European Commission that you can find here.

Please note that regardless of where you live, your personal data will be protected by the GDPR as our business is located within the EEA.

7.2. What are your rights regarding your personal data?

Our Support Team will provide you with information on actions taken within one month of the day of receipt of your request. Only in exceptional circumstances, when we face complex and a high number of requests, we may extend this period of response up to two further months.

Please note that rights may be exercised free of charge. However, unfounded or excessive requests, in particular because of their repetitive character, will lead to the payment of a fee.

Please also understand that, because your privacy is so important for us, our Support Team may need to duly verify your identity and ask you to provide additional information before executing your request.

  • Data Access

You have the right to access the personal data we hold about you. You can request a copy of your personal data, free of charge, through the “Data Download” section in your account settings on the desktop version or via email to privacy@oranum.com.

Upon verification of your identity, your request will be sent to our Broadcaster Support team.

If we consider that your request is manifestly unfounded or excessive (e.g., due to multiple requests in a short period), we may refuse to act or charge a reasonable fee taking into account the administrative costs for providing you with the information.

  • Data Portability

Please note that the following is separate from the right to access your data.

In certain cases, you are entitled to request copies of your personal information in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

For clarification, only the following information can be made available:

The data actively and knowing provided by you (e.g. email address, screen name, etc.)

The observed data provided by you by virtue of the use of the service or the device (e.g. traffic data, location, etc.).

To exercise this right, you can send an email to privacy@oranum.com.

  • Rectification of Inaccurate or Incomplete Data

You have the right to request that we correct any inaccuracies in your personal data.

For this purpose, you can contact our Broadcaster Support team or send an email to privacy@oranum.com.

  • Data Erasure

If you no longer want us to use your personal data, you can request that we erase it and close your account, requests for account cancellation or closure will be considered as a request for the erasure of your personal data.

To close your account, please click “Forget My Data” in the “Privacy Rights” section of your account settings on the desktop version or send an email to privacy@oranum.com.

Your request will then be sent to our Support team who will contact you.

Please note that your request for the erasure of your personal data will be considered as a notice for termination of the agreement you have with us.

Moreover, if your account is inactive for more than six (6) months, we have the right to terminate your account and proceed with the erasure of your data.

Please note that if you request the erasure of your personal information, we will retain some of it for as long as we consider it necessary for compliance with our legal obligations or other legitimate interests as explained above in Section 5. “HOW LONG DO WE RETAIN YOUR PERSONAL DATA?”

  • Right to Object

We process your data for a variety of reasons (see Section 3: “WHY DO WE PROCESS YOUR PERSONAL DATA?”).

Applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on a legitimate interest. If you object to such processing, we will stop processing your personal data for those purposes.

In specific situations, we may have to refuse the execution of your request. This would only be in the cases where we have legitimate grounds to continue such processing or if we have to establish, exercise or defend legal claims.

Please keep in mind that objecting to certain uses of your data may disable the use of your account.

Please also remember that you may ask us, at any time, to stop sending you marketing emails by opting-out in your account settings or by sending an email to privacy@oranum.com.

  • Right to Restriction of Processing

You have the right to request that we stop processing your data, while we resolve any issues.

This is only possible in the following four cases:

  • Accuracy

If you contest the accuracy of your personal data, processing would be stopped while we verify your claim.

  • Legitimate Interest

If you object to a processing activity based on a legitimate interest, you can require the processing operation to be put on hold while we verify your grounds for objection.

  • Unlawful Processing

You can request the restriction of data process if you consider your data is being processed unlawfully, but do not wish for your data to be immediately erased.

  • Data Storage

You can request us to store your data, if you require it to establish, exercise or defend any legal claims, and we have no further need of it.

Despite your request, we may continue to process your data, if we have to establish, exercise or defend legal claims. We will notify you before lifting any restriction.

To exercise this right, you can send an email to privacy@oranum.com.

  • Right to Lodge a Complaint with a Supervisory Authority

If you consider that our processing of your personal data infringes the GDPR or any other applicable national laws, you have the right to lodge a complaint with the relevant supervisory authority (i.e. your local authority or the CNPD).

8. INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the following special rights under the California Consumer Privacy Act (“CCPA”) in addition to any other rights outlined in this Privacy Policy.

Please note that we do not “sell” your personal data, as that term is defined in CCPA.

8.1. Your Right to “Know” and to Request Deletion

You have the right to know the categories and specific pieces of personal data we have collected about you. You have the right to know the categories of sources from which the personal data has been collected, the business or commercial purpose for collecting or selling personal data, and the categories of third parties with whom we share personal data.

You also have the right to request deletion of personal data we’ve collected or maintain. Please note this right is subject to certain exceptions, including without limitation our retaining information as necessary to protect against malicious, deceptive, fraudulent, or illegal activity, to comply with our legal obligations, and for other internal purposes.

To exercise these rights contact us as provided in Section 10 “HOW TO CONTACT US?” below. You can also exercise your right to deletion by selecting “Forget my Data” in the “Privacy Settings” section of your account settings. Please note that any requested disclosures in connection with a request to know will only apply to the 12-month period preceding the request, and you are entitled to request disclosure twice in any 12-month period. You may also download your data as provided on our website or exercise your right to delete by deleting your account as provided in your account settings.

8.2. Personal Information Disclosed

You also have the right to know what categories of personal data we’ve disclosed for a business purpose, and the third parties to whom that information was disclosed.

In the past 12 months, we’ve disclosed for a business purpose the following categories of information to the following parties: Usage/device information (including, without limitation, your IP address, as the case may be) to our business intelligence and analytics service providers (e.g., Hotjar, Google Analytics); Payment/transaction data to our customer/payment service providers; Contact information, device/usage information (including, without limitation, your IP address and the website you are coming from, as the case may), information relating to your Performance and information as regards your interactions with the emails we sent to our marketing and sales partners (e.g. Emarsys, marketing partners promoting our site); identification information, contact information, device and usage information, payment information (as the case may be) to our antifraud service providers and auditing service providers; and contact information to our personal development and training service providers.

8.3. Your Right to Non-Discrimination

You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by CCPA, including but not limited to by denying you services, charging different prices or rates, or providing you with a different level or quality of services. Please note, however, that the exercise of some of your rights (e.g., to delete your data) may render it impossible for us to continue to deliver services to you.

8.4.  Your Right to Use an Authorized Agent

You have the right to designate an authorized agent to make a request under the CCPA on your behalf. To designate an authorized agent, please contact us as provided in Section 10 “HOW TO CONTACT US?” below. In order to verify you have authorized an agent we may require a signed, written authorization from you.

8.5. Do Not Track

Some browsers have a “do not track” feature that lets you tell websites you do not want to have your online activities tracked. Because these features are not yet uniform, we do not presently respond to “do not track” signals. We will however treat any “do not sell” or similar signals as opt-out requests under CCPA.

9. CHANGES TO OUR PRIVACY POLICY

We may occasionally amend this Privacy Policy to reflect changes to our services and the way we are handling your personal data or changes in applicable laws.

If we make any important changes, we will let you know by placing a notice on the relevant site/app and/or contact you directly, using other methods such as email.

To the extent permitted by applicable law, such changes will be applicable from the time they are published on our site/app, unless we specify a date of entry into force. Your continued use of our site/app from that day on would be subject to the new Privacy Policy.

10. HOW TO CONTACT US?

If you have any comments or questions about this privacy policy or generally about our privacy practices, please send an email to privacy@oranum.com or by mail to the address indicated below, and we will get back to you as soon as possible.

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Or

To the attention of the DPO

JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg


We are happy to inform you that we have an employee dedicated to ensuring your privacy, our Data Protection Officer. You can directly reach our Data Protection Officer via email at dpo@oranum.com or by mail at the following address:

To the attention of the DPO

JWS Americas S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg

Or

To the attention of the DPO

JWS International S.à r.l.

44, Avenue John F. Kennedy

L-1855, Luxembourg

Grand Duchy of Luxembourg