Privacy Policy

Choppinglife respects your privacy and has developed this Privacy Policy to present our commitment to protecting your privacy and to explain how we collect, use, and share Personal Data from or about you in connection with your use of the Choppinglife Service.

We encourage you to read this Privacy Policy carefully when using the Choppinglife Service or transacting business with us.

DEFINITIONS
The terms “Choppinglife Service” or “Service” refer to the following: the Choppinglife principal website accessible at www.choppinglife.com and at any of its local versions (the “Choppinglife Site“), the Choppinglife secondary websites (“Secondary Sites”), the Choppinglife video player when it is embedded onto any website (the “Video Player“), the Choppinglife apps and web-apps (the “Choppinglife Applications”) as accessible via any current or future device capable of distributing the Choppinglife Site and/or the Video Player, together with any Choppinglife products, content, channels, software, data feeds, services and functionality.

“Creative Business Partner” refers to entities Choppinglife may cooperate with while carrying out its Services. In particular, Creative Business Partners may include content creators, advertisers, vendors, media agencies and other actors of the on-line marketing sector. Choppinglife belongs to the Souljar Mind Entertainment Network. Some of the Creative Business Partners may also be fully owned by the Souljar Mind Entertainment Network and thus will also be considered as Choppinglife’s affiliates.

“Content” refers to videos uploaded or Articles Posts on the Service, by the Users or by members of the “Creative Business Partner Program”.

The terms “Personal Data,”  “Data Controller,” “Joint Controller,” “Data Processor” and “Processing” used in the present Privacy Policy shall have the same meaning as defined in the General Data Protection Regulation (“GDPR”), or unless, otherwise stated herein, under applicable local data protection laws. Personal Data processed by Choppinglife is referred to as “Data”.

1. General Information
   1.1. Choppinglife’s Role in Processing of Personal Data
   Certain Data from or about you may be collected or otherwise processed when you use the Choppinglife Service, regardless of whether you do so as a Viewer, Visitor, User, or member of the “Partner Program” (as defined in the Choppinglife Terms of Use). 

If you reside in a country that is part of the European Economic Area (“EEA”), the GDPR is applicable to the collection of your Personal Data. If you reside outside of the European Economic Area, local privacy laws are applicable to such collection, generally those of your country of residence.

Choppinglife is a Data Controller when we process your Data based on purposes that we define and using the means we choose. 

We may contract with some service providers to help us implement certain aspects of your Data Processing. In doing so, these service providers act on our behalf following our instructions and thus are considered our Data Processors.

Choppinglife is a Joint Data Controller when Choppinglife and its Commercial Partners process your Personal Data together for a common purpose and using the means we jointly choose.

Our Commercial Partners are independent Data Controllers when they (or their respective Data Processors) process Your Personal Data (for purposes that they define by themselves.  Depending on the applicable local laws and existing technical protocols, Choppinglife’s role is limited to the collection of your consent on behalf of these Commercial Partners, and to the transmission of collected consent to them and providing you with access to their respective privacy policies and consent management mechanisms. 

Choppinglife is a Data Processor when Choppinglife participates in the implementation of some Personal Data Processing operations carried out by our Commercial Partners, who remain Data Controllers.

1.2. Legal Grounds for Processing Personal Data
1.2.1. Legal Grounds
The GDPR provides several legal basis upon which Choppinglife can rely for Processing of Personal Data, namely consent, contractual necessity, compliance with a legal obligation, vital interests of data subjects, public interest or legitimate interest. Similarly, applicable laws may provide for equivalent or additional legal grounds, as explained further below in the country specific paragraphs under Section 8.

Choppinglife Service offers access to Content in association with ads. Presence of both, Content and ads is an essential and non-dissociable part of our Service. Consequently, when we use your Personal Data to display Content and ads we rely on contract as legal ground.

When Processing your Personal Data requires your consent, ex. when your Personal Data is to be used to target the ads that are shown to you to your interests, we ask you to communicate your consent via a positive action (e.g. by clicking the “Accept” button on our Site, Secondary Site or Video Player or through another method defined under the applicable laws). When Processing of Your Personal Data is based on legal grounds other than ‘consent’, we provide you with information regarding the applicable legal ground.

1.2.2. NITDA
Choppinglife may allow Nigeria Information Technology Development Agency to access some of our data for investigative purposes. This exempt websites or applications that integrate the Choppinglife Player and who participate as a Creative Business.

1.2.3. Refusal or Opposition to Processing
When Processing is based on consent or legitimate interest, You can always choose not to consent to Processing of some of your Data, withdraw your consent, or oppose to such Processing (unless the applicable laws authorize us not to take into account such decision) as further explained herein. However, this may limit your ability to take full advantage of the many features we offer and, consequently, deteriorate your user experience. Furthermore, Choppinglife Service offers to Visitors access to a multitude of videos without charging a corresponding fee. This is possible only by associating advertisements to the available videos. Content and ads are both integral parts of our Service and the Choppinglife Service cannot exist without either of them. Not consenting to Processing of your Data will not eliminate or limit the number of ads you are shown; it may simply result in ads which are more repetitive and likely less interesting to you.

1.3. Transfer of Data
The Data collected by us through our Service may be sent to and stored on servers located in data centers primarily located in India, or in the United States and Singapore.

Choppinglife Data Processors, be it Choppinglife’s subsidiaries or companies we contract with for certain Processing operations, may process the Data outside of your country of residence. When applicable, we ensure that legally required, appropriate contractual mechanisms are present prior to transfers of Data outside of your country of residence.

2. Data we collect
   We may collect Personal Data that can identify you directly, such as your name and email address, and other information that does not identify you directly. This Section explains what Personal Data we collect (2.1) and how we collect such information (2.2).

Please note that we may collect Data concerning yourself either during your use of the Choppinglife Site and Choppinglife Applications, or when you use our embedded Video Player on third-party websites or third-party applications.

2.1. Categories of Data We Collect
2.1.1. Data You Provide to Us
We collect Personal Data you provide to us when you interact with the Choppinglife Service, including when you sign up for an account, upload Content, create a playlist or share a playlist with others. For instance, when you register to use the Choppinglife Service, you may provide your name, email address, birthdate, gender, and other similar information. If you are a member of the Choppinglife Creative Business Partner Program, Choppinglife may also collect your payment information, such as your address, bank account or online payment system details and authentication information, as well as billing and contact details depending on the payment system you choose. Note that we do not collect your credit card details. In addition, Choppinglife may collect information you provide to us when you respond to surveys, set your preferences on the Choppinglife Service, directly contact Choppinglife through the Choppinglife Help Center or by other means, or agree to participate in promotions that Choppinglife may offer from time to time. To help you manage your account access rights, Choppinglife  allows multiple log-in accounts to be set up under one Partner account. Consequently, we may collect information you provide to us if you create such log-in accounts.

2.1.2. Usage and Log Data
We collect information when you use the Choppinglife Service or view Choppinglife ads outside of the Choppinglife Service. We may also collect information from or about the computers, phones, tablets, or other devices where you install Choppinglife Applications or otherwise access the Choppinglife Service, depending on the permissions you have granted. Such information may include your IP address, your device ID, the settings of the browser and operating system you use (such as type and version of an operating system or its language settings), your activity on the Choppinglife Service including information about the videos you watch on the Service (e.g. video titles and categories), about the ads you are being shown and your interaction with them, the frequency and duration of your activities, page views, referral URLs, network state, and carrier information.

2.1.3. Account Data from Third-Party Services 
If you choose to log-in, access or otherwise connect to the Choppinglife Service or contact Choppinglife through a third-party service (e.g. Facebook), such method being completely optional and subject to your exclusive decision, we may, in order to execute your choice of a log-in or contact method, collect your email, gender, birthday as well as any other information you make public using that service. Depending on the third-party log-in service used and its current implementation policies, we may also collect additional information you have authorized the third-party service to share with us (such as, for example, your user ID, billing information, etc.).

2.1.4. Third-Party Data
We may, if you authorized such third parties to share such information with us or if otherwise authorized by  the applicable laws, receive from them or share with them information about you originating from other sources, such as data aggregators, public databases, and our Commercial Partners, whether affiliated or unaffiliated entities. Shared data (whether identified, pseudonymized or anonymous and whether collected online or offline) may include information about your interests, demographic data, purchasing behavior, and your online activities (such as websites you have visited and/or advertisements you have viewed).

We may combine the shared information with the information we collect from or about you and use it in the manner described in Section 3 of the Privacy Policy or as otherwise permitted by law.

2.2. How is the Data Collected?
Like many online services, we use, directly or via our subcontractors, various technologies to collect usage data and store your user settings. The Data thus collected helps us propose, protect and improve the Choppinglife Service and personalize your user experience, for example, by enabling you to access videos in a language corresponding to your browser’s settings or in a format compatible with your device.   

Despite the variety of the actual measures deployed, the various technologies used to collect data are commonly referred to as “cookies” and their use is regulated by “cookie laws.” Whenever applicable laws subject the use of cookies to user consent, Choppinglife asks for your consent prior to their use.

A “cookie” is a small data file that is installed on your device. A cookie lifespan is limited to its purpose and does not, in general, exceed 13 months. A cookie expires upon the end of its validity period. A cookie may be deleted before the end of its validity period if you or the technologies you use (e.g. your operating system) do so. The different categories of cookies and assimilated technologies we use are further described below. More detailed information about the use of cookies in connection with advertising on the Choppinglife Service is provided under Section 3.

To learn more about our cookie management rules, please refer to our Cookie Policy. Depending on the country you reside in, you may, at any time, manage your cookie settings and choose the purposes for which you consent to or refuse the use of cookies by accessing the “Manage Cookies” section available on our Service within the EEA.

Cookies and Local Storage
We may use both session cookies and persistent cookies to offer you a high quality Service, better understand how you interact with the Choppinglife Service or with marketing material advertising the Choppinglife Service outside of our Service; to monitor aggregate usage by our users and web traffic routing on the Choppinglife Service; to use technical and automated means to display Content and advertising  based on your Data; to respect the rights of the Content rights holders or that of advertisers and to be in conformity with obligations imposed by applicable laws. We may create a unique device or user ID (“Service ID”) for you and store it in a cookie so we can customize your experience based on your preferences. These uses allow us to create a better experience for you on the Choppinglife Service.

We may collect information through other kinds of local storage (also referred to as “Flash cookies“) and HTML5 local storage, including in connection with features such as volume/mute settings for the Video Player.

Most Internet browsers automatically accept cookies. By changing your browser settings, you can instruct your browser to stop accepting all or some cookies or to prompt you before accepting a cookie from the websites you visit. For further information on disabling cookies or deleting information contained in cookies in general, please click here. Please note that disabling cookies or deleting information contained in cookies or Flash cookies may interfere with the performance and features of the Choppinglife Service, including the Video Player. For example, we may not be able to store your preferences (such as the language to be used by the Service) or login information (such as keeping your connection session active thus allowing you to be automatically recognized by the Choppinglife Service when you repeatedly access it through the same device) or use technical means to display  Content and advertising based on your online viewing habits.

Web Beacons, Pixels and other Trackers
Web beacons or pixel tags are similar to cookies and can be embedded within web pages, videos, or emails. These technologies are mainly used to learn whether you have viewed a particular web page, ad, or email message; and determine other usage details including the time and date on which you viewed Content, the IP address of your computer, and the URL of the web page from which the Content was viewed.

Mobile Device Identifiers and Software Development Kits (“SDKs”)
We may use or work with third parties, including our Commercial Partners and service providers, who use mobile SDKs to collect information such as advertising identifiers (e.g., “ad-ID” or “IDFA”) and information related to how mobile devices interact with the Choppinglife Service. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented (a mobile SDK is a mobile app version of a pixel tag or beacon, described above). For instance, we may use this technology to analyze how you interact with Content and advertisements and to enable analytics or other features through mobile devices.

3. PURPOSES FOR DATA PROCESSING
   3.1. Purposes for which Data is Processed by Choppinglife
   3.1.1. General
   We receive or collect Data, either directly or via our service providers, because we are passionate about creating an engaging and relevant experience for our users, and to ensure that the rights of Content right holders and advertisers are respected. We may also share some of your data with Choppinglife’s affiliated companies (Vivendi group’s wholly owned companies) or with other Commercial Partners to better understand what you may be interested in.

We use all of the legitimately collected or received information to help us provide and support the Choppinglife Service with a first-class user experience that is adapted to each user’s tastes, as varied as they may be. The way we use the Data about you depends on how you use the Choppinglife Service.

Note that videos accessible on our Service, be it Content or video ads, do not belong to Choppinglife. Instead, they are provided by various right holders who, by sharing their videos on Choppinglife Service, decide which of their videos they make available to you.

As a content hosting platform Choppinglife does not curate the videos that are accessible to you. It means that we do not have a team of content editors proposing video selections to you that they believe are adapted to your individual taste.

Our Service offers videos in multiple languages that can be accessed from a number of electronic devices and through different browsers. We use cookies to detect the linguistic and technical settings of your device and browser to show you videos that correspond to your device setting, i.e. in the language your browser is set to and in a format your device is capable of accessing.

You will find in the present Section detailed information about the different purposes your Data is processed for.

3.1.2. Purposes for which Data is Processed
Choppinglife may process the Data for the following purposes:

Provide, Improve and Develop the Choppinglife Service. We are able, through technical and automated algorithms, to deliver the Service and to display Content and advertisements based on your Data collected on our Service. We analyze such Data to understand how you use and interact with the Choppinglife Service and discover the things you’re interested in on and off our Service and ultimately provide you with the best user experience we can offer. For example, we collect your authentication data to allow you to connect to your account, and we collect information on your language setting preferences to provide you with the Choppinglife Service in the language of your choice. We may conduct surveys and research, test features in development and analyze the information that we have in order to evaluate and improve our existing products and services, develop new offerings or features and conduct maintenance and troubleshooting activities.
Communicate with You. We may use your Data to send you marketing communications, communicate with you about the Choppinglife Service and update you about our policies and terms. We also may use your information to respond to you when you contact us, or for any other purpose that is disclosed to you at the time we collect the Data or that is related to a request made by you or related to you. To learn about opting out of promotional communications, please see the information we have provided in Section 8 below (“Your Privacy Rights”).
Show and Adapt Ads. Choppinglife offers its users the opportunity to watch numerous videos without charging any fee in return. Such free of charge service can only be possible thanks to the presence of advertisements. We may use Data we have, including information received from our Commercial Partners, to evaluate and improve our advertising and analytics systems so that the ads shown to you on and off our Services are customized and of real interest to you.  We also use Data to limit the quantity of advertisements you are shown on our Service to allow you to fully enjoy the Content. By processing some of your Data we also measure the effectiveness and reach of ads and services. Your Data may be shared with our Commercial Partners to inform them about your decision whether or not to allow processing of your Personal Data and, if you agreed, to allow them to estimate whether the products or service for which they run advertising campaigns may be of interest to you. To learn about opting out of interest-based or online behavioral advertising, please see the information we have provided in Section 8 below (“Your Privacy Rights”) or exercise your choices via Choppinglife’s “Manage Cookies” section available on our Service, provided that you reside in the EEA.
Pay You.  If you are a member of the Choppinglife Partner Program, we use your billing information, such as your billing address or payment methods details, to proceed with payment of sums generated under our Partner Program monetization features. If you choose a third-party payment method, we will communicate to the payment service provider of your choice all information necessary to process due payments and may receive from such payment service provider the receiving account details and related payment confirmations. The exact information communicated or received depend on the payment service provider chosen, the payable amounts and then-current requirements of laws and regulations applicable to financial transactions. Note that we do not use or otherwise access your credit card information.
Identify Your Geographic Location. We may collect your device’s location data (limited to the city level only). This information not only allows us to serve you Content related to your local area, such as local news and sports videos, but enables us to ensure the respect of Content geo-restrictions imposed by the Content right holders. This Data may also be used to tailor advertising to you based on your location by, for example, not showing you ads for services unavailable at your location. 
Elaborate Aggregated or Anonymized Statistics. We may “de-identify” information about you and/or other users, which means that the Data is modified (anonymized or aggregated with other information) so it no longer personally identifies you. We may then use this “de-identified” information for any legitimate internal and external business purpose, including for research and analysis of the Choppinglife Service, improving our capacity to deliver customized advertisements, and for promoting our Service to future users, Commercial Partners and other business partners. In particular, we may also share your aggregated Data (i.e. information in a form that does not allow its recipients to identify you) with advertisers and Content owners to provide them with meaningful insight about the audience of their ads or Content on our Service.
Ensure Safety and Security of Choppinglife Service and its Conformity with Applicable Laws.  We may use the Data to ensure the security of our Service and anti-fraud protection. Our dedicated engineering teams do so by using automated procedures and advances technologies such as data encryption and machine learning. Consequently, your Data may be processed as part of investigation of suspicious account activities or violations of our legal terms and policies. In conformity with our legal obligations, Choppinglife maintains connections logs linked to each user’s account activities and communicates them, if requested to do so pursuant to applicable legal procedures, to duly authorized public authorities.
3.1.3. Specific Purposes for which Data is processed when operating the Enterprise Solution Video Player
We continuously work on improving the Choppinglife Service, including by developing different versions of our Video Player. As part of this effort, Choppinglife may offer to content partners, subject to specific financial conditions, the possibility to use our Video Player for distributing Content without any advertising being associated to it (the “Enterprise Solution Video Player”).  

Content Partners having chosen this new solution (“Clients”) integrate this Enterprise Solution Video Player on their websites or their other digital properties (ex: mobile applications) and pick Content they wish to make available to you.  

When Clients use the Enterprise Solution Video Player, Choppinglife remains Data Controller for the cookies deployed by that player and related processing of your Personal Data. As the Enterprise Solution Video Player is not designed to show ads, Choppinglife does not use advertising cookies nor process your Personal Data for purposes which are related to advertising, be it contextual or targeted. For further details on the cookies used by the Enterprise Solution Video Player, please refer to our Cookie Policy.

When you watch Content made available by Clients through the Enterprise Solution Video Player they chose to use, you are visiting such Clients’ digital properties (ex: their websites or mobile applications). Consequently, other cookies than those used by our Enterprise Solution Video Player may be deployed by the Clients or by the third parties they work with, as well. Choppinglife has no control over these cookies and the use of data they collect. For further information about cookies used by Clients and the third parties they work with and corresponding processing of your Personal Data, please refer to the privacy and cookie policies of the Clients’ digital properties that you visit.  

3.2. Purposes for which Data is Processed by our Commercial Partners
When you watch Content or ads on the Choppinglife Service our Commercial Partners may collect and further process, either directly or via their respective subcontractors, information about you and your use of our Service. They may use this information, including in combination with other data they have access to, in order to adapt content and ads that may be shown to you on our and on third parties’ services. While doing so, our Commercial Partners process your Personal Data in their capacity as Data Controllers and follow privacy policies that are their own.

We may disclose or share your Data with our Commercial Partners. In particular, we and our affiliated companies (Vivendi group wholly-owned companies) may share the information we have about you in order to learn more about your tastes and let each of the Vivendi group wholly-owned companies, whose services you might be using, offer you more personalized services, products and ads. 

When advertisements are shown to you on our Service, some Data is disclosed to our Commercial Partners to allow delivery of an ad on the device you use. Such disclosure is made in accordance with  industry-wide standard technical protocols. Such Data  may include your digital identifiers, information about the device you use and its settings, the url of a website, the content and the associated ad you are watching, your approximate location, as well as the socio-demographic or interest-based category we think you may belong to based on the information we have collected from or about you and/or obtained from third parties. The actual categories of Data disclosed depend on your use of our Service, the technical protocol used and, when applicable, on the actual Data usages you consented to. When applicable, the disclosed Data contains information about your privacy choices, i.e. about the purposes you consented your Data to be Processed for.

We may also share the same information listed above  with advertisers. For example, we may tell an advertiser how its ads performed, or how many people viewed its ads or installed an app after seeing an ad. We can also provide such advertiser with non-personally identifying demographic information (such as a the following categorizations: female between 25 and 30 years of age, living in New York) to these advertisers to help them understand their audience or customers, but only after the advertiser has agreed to abide by strict confidentiality obligations.

When disclosed Data is used by a Commercial Partner for its own purposes, it is that Commercial Partner who is the Data Controller for the Processing it undertakes.

Choppinglife works with a large number of Commercial Partners. The list of Choppinglife’s Commercial Partners is published on our Service and may be consulted at all times from within the “Manage Cookies” section. Note that it does not mean that when you watch a video on our Service all of these Commercial Partners process your Personal Data. Only the Commercial Partners (or their technical service providers) involved in posting the ads shown to you or publishing Content that you watch on Choppinglife Service process your data. The identity of our Commercial Partners who process your data depends on the Content and ads you watch on our Service.

As a Data Controller, each Commercial Partner determines the purposes for which it wishes to process your Personal Data. These purposes may include the development, improvement and delivery of their services, audience and service analytics, personalization and adaptation to your centers of interest of their content, commercial offerings and ads, whether on or outside of the Choppinglife Service,  conformity with their respective contractual and legal obligations, such as, for example, geographic restrictions of their content exploitation rights, calculation of applicable fees or anti-fraud measures. You may learn more about each Commercial Partner’s Processing purposes and legal ground(s) by accessing their IAB Vendor registrations or privacy policies through links available within the “Manage Cookies” section of our Service accessible from the EEA.

When our Commercial Partners’ collection  or processing of your Personal Data depends on your consent, Choppinglife asks you for such consent on behalf of our Commercial Partners. Consequently, you may, at all times, manage your consent Commercial Partners’ collection or processing of your Personal Data and indicate the purposes you choose to consent or not to consent to by exercising your choice on the “Manage Cookies” section available on our Service and accessible from the EEA. You may also exercise your right by accessing the Commercial Partners’ respective privacy policies, as accessible from  the Commercial Partners List.

Note that refusing the use of your Personal Data for ad-targeting purposes will not block advertisements. You will still see ads, but they will be less pertinent to your interests.

If you wish to learn more about the purposes for which our Commercial Partners process your Personal Data and the legal grounds such processing  can be based on, we advise you to read their respective privacy policies. For reasons inherent to the dynamic character of the online activities, this list of Choppinglife Commercial Partners may evolve. The list will be updated periodically, and we invite you to consult it regularly for the most up-to-date information.

4. DATA RECIPIENTS
   We may share personally identifiable or non-personally identifiable information collected from or about you with third parties, or allow you to share your personal information with third parties, such as social networks, as explained further below (“Data Recipients”). We require such Data Recipients to adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements that we may enter into with them.

4.1. Third Party Login Services
If you connect to the Choppinglife Service through your Facebook or Google accounts, you may choose to share information about your activities on the Choppinglife Service with Facebook or Google. Furthermore, if you visit Choppinglife while logged-in to Facebook or Google, then those entities may record your browser details and combine technical information from your web browser with other information that each of them already knows about you. Your decision to share information about your activities on the Choppinglife Service within your Facebook or Google account may result in Choppinglife sending relevant information about you to Facebook or Google. Facebook or Google may then make that information visible to its own users in accordance with applicable law, its own data and privacy policies, and your Facebook or Google privacy settings. We recommend you familiarize yourself with Facebook’s and Google’s respective data and privacy policies and available account privacy controls. We remind you that Choppinglife is independent from these third-party companies and that any privacy settings you might have chosen on the Choppinglife Service are not applicable on Facebook, Google or any other social network account.

4.2. Commercial Partners
We work with a number of Commercial Partners who help us offer and improve the Choppinglife Service. Such Commercial Partners include, for example, Content uploaders,  and other actors of the digital industry. We may disclose information collected from or about you to such Commercial Partners (or their authorized service providers) when we are legally authorized to do so, but such disclosure is always accompanied by appropriate technical, organizational or contractual measures aimed at ensuring the integrity and security of your information (e.g., aggregation, anonymization, etc.).

In particular, we may share information, generally in the aggregated, encrypted or anonymized form, about you with advertisers and advertising-related service providers, for the purposes described above under Section 3.2, including for technical reasons (e.g., to deliver advertising videos on your screen), to make ads relevant and interesting to you or measure and improve the effectiveness of advertising campaigns. Note that we do not share directly identifiable information about you (such as your email address) with advertisers and advertising-related service providers.

4.3. Service Providers
Like most companies, we contract with third parties to provide us with specialized services in connection with our business activities. The services we contract vary and evolve in time and include:  payment solutions (e.g. PayPal or Payoneer), analyzing and processing data (e.g. provision of analytics software that helps us  improve ads relevancy), hosting our websites and the content, providing customer support, communicating with you  (e.g. email or push notification systems) or otherwise help us provide the Choppinglife Service.

When the delivery of these services requires so (and if you consented so or if we are otherwise authorized to do so), we share some of your Data with our Service Providers. Our Service Providers commit to confidentiality obligations in conformity with the present Privacy Policy and with the contracts we sign with them.

4.4. Audience Measurement Providers
Our Commercial Partners, such as content providers and advertisers, seek to measure the performance of their videos across many platforms, including the Choppinglife Service. Accordingly, Choppinglife may use and permit the use on its Service of independent, industry-standard, third-party measurement solutions (e.g. Nielsen or comScore) that enables us or our Business Partners to include your video views in our or their measurement statistics. We may also share our own usage statistics, in anonymized or aggregated form, with these Business Partners.

To learn more about your choices with respect to audience measurement software, please see the information we have provided in Section 8 (“Your Privacy Rights”).

4.5. Public Authorities and Legal Counsels
In some instances, we may be required to disclose information from or about you to public authorities or to legal counsels without notifying you or giving you the opportunity to object. We may disclose your information in good-faith to protect the legal rights of Choppinglife, of our affiliates or Commercial Partners, and of each of our respective equity holders, directors, officers, employees, or agents, and technical service providers acting as our processors or sub-processors; to protect the safety and security of our users   or of third parties; to enforce our Terms of Use; to prevent fraud; for risk management purposes; and to comply with or respond to the law, a legal process, or a request for cooperation by a government entity. However, it is Choppinglife’s policy, whenever reasonably possible and legally permissible, to promptly notify you upon receipt of a subpoena or court order requesting your Data and to not produce your Data until we receive such subpoena or court order, so that you will have adequate opportunity to initiate appropriate legal proceedings.

Furthermore, if you notify us that you believe your legal rights have been violated by Choppinglife or by another user of the Choppinglife Service, we may provide the Data that you provide to us to others to the extent that we believe it is necessary to evaluate and respond to your complaint.

4.6. Third Parties in Connection with certain Corporate Transactions
If we sell all or part of our business, make a transfer of assets, or are otherwise involved in a change-of-control transaction, or in the event of bankruptcy, we may transfer or share information from or about you to one or more third parties as part of the transaction, including as part of the due diligence process. In such case, your Data would be transferred or shared only as an integral part of the underlying transfer of the Choppinglife Service (or part thereof) and not sold separately to third parties.

4.7. Parties you Consented to or to whom you Choose to Share Your Data
Certain functions within the Choppinglife Service may give you the option to share videos through our Video Player, along with any information you want to share, for example, through your own websites, applications or social network channels, such as Facebook or Twitter.

If you hold an account with Facebook or Twitter, you may choose to share information about a video on the Choppinglife Service with Facebook or Twitter users by using the dedicated sharing feature on our Service. Such sharing is only possible while you are logged-in to your Facebook or Twitter accounts. Your decision to share information about a video on the Choppinglife Service may result in Choppinglife sending relevant information about you to Facebook or Twitter. Facebook and Twitter, pursuant to their respective data and privacy policies and to your Facebook or Twitter privacy settings, may process your Personal Data relevant to the sharing of such video.

Lastly, we may also share any information from or about you with any party when we have your consent or when you otherwise choose to share such information (e.g. sharing your contact information to an uploader whose content you have reported on our Service, if necessary, or sharing your information in the scope of a marketing study you agreed to participate in, etc.).

5. DATA SECURITY AND ACCOUNT ACCESS
   5.1. Data Security
   The security of your Data is important to us. Our goal is to make you feel confident and safe when using the Choppinglife Service.

We use a variety of physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, and modification. For example, we take steps to limit access to sensitive information from or about you to only those Choppinglife employees, agents, and contractors who have a legitimate business reason to access such information. We also use measures like encryption and hashing to help protect sensitive information when in transmission, and firewalls to help prevent unauthorized persons from gaining access to your Personal Data. We also use techniques such as data aggregation to render it more difficult to link and trace information to you.

Despite these efforts, there is always a possibility that a breach in data transmission or storage may occur. We want you to feel confident in our security when using the Choppinglife Service, but we cannot guarantee the absolute security of Data at all times. We advise you to exercise caution and, in particular, to use a unique password for your Choppinglife account, i.e. a password that you do not use for any other service you have an account with (which could prevent, in the event your Choppinglife password confidentiality is breached, unauthorized access to these other accounts), to change your password if you suspect its fraudulent use and contact us if you notice any suspicious activities on the Choppinglife Service.

5.2. Account Access
If you have an account with us, your Personal Data can be reviewed online from within your account settings. You can also update your information either via the account settings or by contacting us (see Section 11.5 “Contact Us” for more details).

Your account is unique to you and protected by a user-generated password.  We advise you to choose a unique and complex password, not to disclose it to third parties, and to change it if you have any doubts as to its confidentiality. Do not hesitate to contact us if you observe any suspicious activity on your account. Note that if you use third party log-in solution (e.g. Facebook or Google), Choppinglife does not store or manage your password. Instead, it is that the policies of the third party log-in solution that apply to the management of your password.

Please note that if you allow others to use your account (including by authorizing others to set up specific accesses within your account), they may be able to view information about your account (e.g. your email address) or any of the playlists created within your library (e.g. videos you have viewed). You should exercise caution while handling and disclosing your Personal Data on our Service and avoid sending it through insecure email. Please refer to the Federal Trade Commission’s website at for further information on how to protect yourself from identity theft.

6. DATA RETENTION
   Data is stored electronically on Choppinglife’s servers or with our cloud service providers and is kept only as long as necessary for the purposes set out in this Privacy Policy or as otherwise required by applicable laws.

We have a legal obligation to retain some Data, such as information associated with the identity of an account holder (retained for a period of one year following the deletion of an account) or invoicing details. If you ask us to delete your Data, provided that its retention is not required or expressly authorized by the applicable laws, the Data is deleted or anonymized and used for statistical purposes only.

Please refer to Section 8 below for further details on your rights in relation to Your Personal Data.

7. YOUTH RESTRICTIONS AND PARENTAL CONTROL
   Children who are under the legal age in their country of residence to enter into an agreement with a digital service provider are defined in this Privacy Policy as “Juniors” and are not permitted to register with Choppinglife, i.e. are not allowed to open an account with our Service.

The age limit that determines whether a person is a Junior is defined by the laws applicable in your country of residence and generally varies from 13 to 16 years of age.

In addition, Juniors should not use or access our Service without the involvement and consent of a parent or guardian.

Choppinglife Service is intended for the general public. It does not specifically cater to any particular age or interest group. When you visit our Service, we do not know your age. Despite lacking that knowledge, we have designed some Service features protecting young audiences. In particular, a parental control is activated by default when using our Service.

If you are the parent or legal guardian of a Junior, and that child has somehow registered with Choppinglife without your approval and contrary to our Terms and Conditions, please contact Choppinglife’s support team, available 24/7 through the Choppinglife Help Center to initiate an account deletion procedure. When submitting your request, please provide us with a sworn statement confirming that you are either a parent exercising full parental rights or a legal guardian of the child and indicate your full name and address, the child’s full name and address, your relationship to the child and your email address. Choppinglife will use this information only to process your request and verify that you are the child’s parent or legal guardian, and for no other purposes.

8. YOUR PRIVACY RIGHTS
   8.1. General
   Depending on your country of residence, you may be entitled to access, correct and/or delete the Data you have provided to us, by requesting to do so through the setting of your account, or by reaching out to the Choppinglife Help Center via the dedicated section. When justified by the circumstances of your request, we may ask you for a copy of your ID or any other relevant documents, in order to confirm that you are indeed the data subject or a person authorized to exercise these rights on behalf of a data subject, and to determine the laws and procedures applicable to your request.

If you are a resident of EEA, UK, Switzerland, California, Brazil, Korea or Turkey (Türkiye), you may find in this Section (Sections 8.5 through 8.9)  some specific information and procedures applicable under the laws of your country of residence.

8.2. Change of Privacy Settings for Promotional Communications
You may decide not to receive promotional communications from Choppinglife by accessing your account and clicking on “Manage Email Notifications.” You may also communicate to us your decision not to receive promotional communications by clicking the “unsubscribe” link in a particular promotional message.

Note that you cannot opt out from receiving all communications from Choppinglife, including administrative messages, service announcements, and messages regarding the terms and conditions of your account because those may contain important information necessary to using the Choppinglife Service.

You can choose to receive push notifications from Choppinglife on your device. If you do not wish to receive push notifications, you can use your device’s settings to turn them off.

8.3. Options for Third-Party Online Behavioral or Interest-based Ads on Websites (including Mobile Websites)
Choppinglife offers its users the ability to make choices about the use of their information for ad targeting. To learn more about how to exercise your ad preferences, please refer to our Cookie Policy.

Some of the third parties that collect or participate in the collection of information from or about you on the Choppinglife Service in order to provide more relevant advertising to you participate in the DAA Self-Regulatory Program for Online Behavioral Advertising. This program offers a centralized forum where individuals can declare their choices about the use of their information for online behavioral advertising. To learn more and to make choices about the use of your information for online behavioral advertising on websites, please click here. Please note that if you exclude online behavioral advertising using this method, this choice will only apply to the specific browser or device from which you opt out.

In addition, some of these third parties may be members of the Network Advertising Initiative (“NAI”), a cooperative of online marketing companies that offers a centralized tool for opting out of interest-based advertising delivered by each of its member companies. If you would like to obtain more information about interest-based advertising and the NAI and make choices about their members’ use of information from or about you on websites, please click here. Please note that if you exclude interest-based advertising using this method, this choice will only apply to the specific browser or device from which you opt out.

8.4. Options for Third-Party Online Behavioral or Interest-Based Ads within Mobile Apps
You can define your preferences regarding the use of your information or ad targeting within mobile apps by accessing a cookie preference module available directly within the settings of Choppinglife’s mobile applications.

Some of the third parties that collect or participate in the collection of information from or about you on the Choppinglife Service in order to provide more relevant advertising to you within mobile applications participate in the DAA Self-Regulatory Program for Online Behavioral Advertising. This program offers a mobile application called the “AppChoices,” which provides a centralized location where users can make choices about the use of their information for online behavioral advertising within the mobile application environment. The AppChoices application can be downloaded from your mobile device at https://youradchoices.com/appchoices or from your device’s app store. Please note that if you exclude online behavioral advertising using this method, this choice will only apply to the mobile device you used to do so.

You may also exercise your choices by accessing your device settings and selecting “Limit Ad Tracking” (for iOS devices) or “Opt out of Interest-Based Ads” (for Android devices), which will allow you to limit our use of information collected from or about your mobile device (such as precise location data) for the purposes of serving online behavioral advertising to you.

8.5. Additional Information for EEA Residents
8.5.1. Data Subjects Rights
Individuals located in the EEA (European Economic Area, UK and Switzerland) have certain statutory rights in relation to their Data that they can exercise with Data Controllers, i.e. with entities in charge of processing of their Data. Subject to statutory exemptions, if you reside in the EEA, you have the right to request from Choppinglife SA the access , update, deletion, correction or transfer of your Personal Data that Choppinglife SA processes in its capacity of a Data Controller. You can do so by using the settings and tools provided in your Choppinglife account or by contacting Choppinglife SA. If you encounter troubles using the settings and tools, or if you do not have a Choppinglife account, reach out to the Choppinglife Help Center via the dedicated  section or send a letter to the attention of our Data Protection Officer at the following address: Choppinglife SA, 140 Boulevard Malesherbes – 75017 Paris, France. Please include within your request a clear description of your request and information about your country of residence, along with any information allowing us to identify your Choppinglife account (such as the email address used to log into such account) and to confirm your identity.

Depending on the nature of your request, you may be asked to provide further documents as needed to verify your identity and the conformity of your request with legal requirements and to identify the Personal Data that your request pertains to.

Furthermore, you are entitled to define and communicate to us the rules applicable to your Data upon your death.

Note that, in compliance with applicable laws, some of your Data may not be communicated, rectified or deleted despite your request to do so. In such case, we will inform you about our incapacity to fully comply with your request and the reasons behind that decision.

We remind you that when using the Choppinglife Service, your Data may be Processed by different entities acting in their capacity of a Data Controller. If we receive from you a request that pertains to Data processed by another Data Controller, we will, if reasonably possible, transmit the request and your contact details to such Data Controller and inform you about it.

For further details regarding Choppinglife role in the processing of your Data, please refer to Section 1.1.

8.5.2. Privacy Shield
Your Personal Data may be processed by Choppinglife Inc. a wholly owned subsidiary of Choppinglife SA. At the date of publication of this latest version of our Privacy Policy, Choppinglife Inc. is registered with the Privacy Shield and committed itself to respecting set standards in processing Personal Data of EEA and Swiss data subjects. Choppinglife has designated the EU Data Protection Authorities or the Swiss FDPIC, as applicable, as the entities competent for dispute resolution purposes under the Privacy Shield proceedings. You may regularly verify Choppinglife Inc.’s self-certification with the Privacy Shield by consulting the list of Privacy Shield participants which may be found here. If you have a question or wish to file a complaint regarding the covered data, please reach out to Choppinglife Inc whose contact information can be found in the “Contact Us” section of this Privacy Policy. Please include within your request a copy of your ID, information about your country of residence, and any information allowing us to identify your account on the Choppinglife Service. Choppinglife Inc. will reply to you within 30 days.

If you are not satisfied with the final Choppinglife Inc. decision regarding your complaint, you may use the other appeal venues defined in the Privacy Shield. In particular, upon exhaustion of the appeal rights with Choppinglife Inc. you may file your complaint with the entity declared by Choppinglife Inc. with the Privacy Shield as competent for dispute resolution purposes, and if not satisfied with that entity’s decision, use the arbitration procedure provided for under the Privacy Shield. For further information on applicable procedures please visit the Privacy Shield website.

Note that since the invalidation of the Privacy Shield, Choppinglife no longer relies on Choppinglife Inc.’s participation in the Privacy Shield as the legal ground for international transfers of Personal Data of EEA data subjects to Choppinglife Inc. For information on the international transfer of data, please review Section 10 ‘International Data Transfers and Standard Contractual Clauses’ below.

8.6. Additional Choices for the Residents of the United States of America
8.6.1. Additional Choices for California Residents
8.6.1.a. Personal Data Processing Information under the California Privacy Laws
8.6.1.a.i. General
If you are a California resident, in addition to any other information you may find in this Privacy Policy, this section is intended to provide you with specific information required under the California Consumer Protection Act (“CCPA”) ”) as amended by the California Privacy Rights Act, collectively  referred to as “CPRA”. In particular, in this section, we explain your rights, list the categories of Personal Information (“PI”) that we collect or use and explain whether and how, in the preceding 12 months, we have collected, disclosed, Sold or Shared your PI.

The terms “Personal Information,” “Business,” “Third Party”, “Service Provider”, “Contractor”, “Cross-Context Behavioral Advertising“, “Sale”, “Share” and “Sensitive Personal Information”  used in this section have the same meanings as defined in the CPRA.

If you have an account with Choppinglife, we identify you by the email address you use to log-in or any other credentials available for use as log-in from time to time. However, if you do not have an account, in most cases, we rely on a unique online identifier to identify and recognize you.

When you access our Service, a Choppinglife cookie (i.e. a small text file) is dropped on your device’s browser. If you use different devices or different Internet browsers to access our Service (and unless you do so as a logged-in user, in which case we might be able to recognize you regardless of the device or browser used), you are assigned a different Service ID for each of your device/ browser combinations. In other words, if you first accessed the Choppinglife Service using Firefox on your laptop, but then visited it on your phone using Chrome you will appear to us as two distinct users. Unless you access the Choppinglife Service as a logged-in user, any information that we might have about you is attached to that Service ID.

Due to legal rules applicable to our activities, the lifespan of our cookies is limited to 13 months. Once the 13-month period comes to an end, the Choppinglife cookie storing your Service ID expires. The cookie may also be deleted before the end of that 13-month lifespan; for example, it may be deleted intentionally by you or through your browsing settings.  If you continue to use our Service, a new Choppinglife cookie will be dropped on your browser and a new Service ID will be assigned to you. 

As already mentioned in this Privacy Policy, we do not cross-reference Service IDs that are assigned to you on our Service. Unless you are a logged-in user (in which case we recognize you through your account credentials regardless of the number of Service IDs created for you), each new Service ID represents to us a new user. For that reason, and unless you are a logged-in user, if you decide to exercise any of your CPRA rights, your decision will only be applied to the Service ID under which we recognize you. In particular, if you use the Choppinglife Service on several devices or Internet browsers, your decision to Opt-Out of the Sale and Share of your PI needs to be expressed on each such device or browser.

8.6.1.a.ii. Collected Personal Information: Categories, Sources and the Business or Commercial Purposes It is Used for
We may obtain your PI either from you (directly or indirectly), from companies with whom we have business relationships or from our affiliates. We receive your PI directly from you when you create an account or otherwise communicate with us or interact with our Service. We collect or generate information about you when you use our Service. Some of the PI that we collect might belong to the category of Sensitive Personal Information (“SPI”). We receive your PI from companies with whom we have business relationships when, for example, we engage them to help us operate our Service. Your PI may be shared with and by our affiliates if they participate in operating our Service or if you use their services.

Additionally,   in order to enable the delivery of ads, certain PI may be disclosed to us by advertising partners wishing to advertise on our Service.

We disclose your PI to our Service Providers, Contractors and Third Parties. When such disclosure is done for monetary or other valuable consideration, it is referred to under the CPRA as a Sale. When it is done for the purpose of targeting of ads to a consumer based on  PI obtained from such consumer’s activity across businesses, distinctly-branded websites, applications or services other than the Choppinglife Service, it is referred to under the CPRA as a Share.

Note that the Choppinglife Service is an advertising-based content hosting platform, meaning that presence of both Content and ads is its essential feature. Our business purposes include: enabling you to use your Choppinglife account and any of the available Service features, using technical means to display  Content and ads to you on the Choppinglife Service including to tailor the content and ads to your needs and interests; delivering and monitoring of our technical platform; processing payments that may be due to Content uploaders; using data analytics services aimed at improving our Service and providing required reporting to content uploaders and advertisers; ensuring security and preventing fraud, abuse or illegal activity; engaging service providers; providing customer support and ensuring our compliance with legal or industry standard rules; and establishing, exercising or defending legal claims.

The PI that we collect may be disclosed to (i) our affiliates, (ii) our advertising partners participating in the delivery of ads on the Choppinglife Service (e.g. advertisers, media agencies), (iii) our service providers (data analytics services, technical service providers, payment facilitators), and, (iv) if required so by applicable laws, public authorities. When we disclose your PI, we only do so to the extent needed to achieve our business purposes or those of our affiliates and to comply with the applicable laws or regulations.

In the tables below you will find detailed information regarding the PI we collect, disclose, Sell and Share and the purposes we do so.

8.6.1.a.ii.1. Collected PI: Categories, Sources and the Purposes It is Used for and the Categories of Third Parties to Whom Your PI is Disclosed
The following categories of PI may be collected by us from or about you and disclosed in the preceding 12 months for the below-listed purposes:

CATEGORY OF PI    EXAMPLES OF PI (DEPENDING ON THE PI YOU PROVIDE TO US AND YOUR USE OF OUR SERVICE)    BUSINESS OR COMMERCIAL PURPOSES THE PI IS COLLECTED, SHARED, SOLD OR DISCLOSED FOR    CATEGORIES OF THE SOURCES THE PI IS COLLECTED FROM    CATEGORIES OF THIRD PARTIES TO WHOM PI MAY BE DISCLOSED DURING THE PRECEDING 12-MONTH PERIOD
Identifiers    A real name, alias, postal address, unique digital identifiers linked to your device, browser or application (ex. Service ID, third party online identifier, IP address, account credentials (email address, username, and any other account credentials as provided from time to time), account name, a copy of official ID, or other similar identifiers that you may communicate to us directly or indirectly when using our Service)    -To comply with a legal obligation
-To provide you the Service and achieve our business purposes including display of Content and ads    -You; either directly or indirectly
-Our Service Providers
– Business or persons providing services to us (ex. payment solution providers (when you authorize them to disclose to us your account information necessary for us to pay you))
– Advertising partners
-Providers of 3rd Party connect features (ex. Apple connect)
-Our affiliates
-Advertising partners (digital IDs, IP address only)
-Public authorities
– Our affiliates
-Business or persons providing services to us
Your Content    Your videos, comments, reactions, etc.    -To provide you the Service and achieve our business purposes including display of Content and ads    You    -End-user of the Choppinglife Service
-Our affiliates
-Business or persons providing services to us
Commercial Information    Revenues generated, Payment method details for payments made by us (to the exclusion of credit card details)    -To comply with a legal obligation
-To provide you the Service and achieve our business purposes including display of Content and ads    -You, indirectly (information generated by us based on your Content activity)
-Business or persons providing services to us (ex. payment solution providers (when you authorize them to disclose to us your account information necessary for us to pay you))    -Content right holders
-Public authorities
-Payment solution service providers
-Our affiliates
-Business or persons providing services to us
Demographic Information    Date of birth, gender, language, geographic location    -To comply with a legal obligation
-To provide you the Service and achieve our business purposes including display of Content and ads    – You; either directly or indirectly
-Providers of 3rd Party connect feature (ex. Apple connect)    – Advertising partners (age range, either deduced or actual), gender, language and geographic location only
-Business or persons providing services to us
-Public authorities
-Our affiliates
Internet or other electronic network activity information    Browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement, including information on the upload of the Content    -To comply with a legal obligation
-To achieve our business purposes    -You; indirectly
-Business or persons providing services to us
-Our affiliates    – Advertising partners
-Business or persons providing services to us
-Public authorities
-Our affiliates
Geolocation data    -IP address
-Postal address    -To comply with a legal obligation
-To achieve our business purposes    You, indirectly    -Advertising partners (IP address only)
-Business or persons providing services to us
-Public authorities
-Our affiliates
Device information    Device used, language and other settings, operating systems    To provide you the Service and achieve our business purposes including display of Content and ads    -You; indirectly
-Business or persons providing services to us    – Advertising partners
-Business or persons providing services to us
-Our affiliates
Inferences drawn from PI to create your profile    User segments based on your deduced geographic location, age and/or viewing preferences and behavior     To achieve our business purposes    -You, indirectly (information generated by us based on your activities)
-Our affiliates    – Advertising partners
-Business or persons providing services to us
-Our Content right holders
-Our affiliates
Content of your communication with us    Any information that you might provide to us    To provide you the Service and in particular to provide assistance requested from our support service    You; directly or indirectly    -Business or persons providing services to us
-Public authorities
-Our affiliates
-Right holders (ex. when you notify to us a possible copyright infringement)
Sensitive Personal Information    Social security, driver’s license, state identification card, or passport, to the extend you communicate it to us (ex. as part of your exchanges with our Support service)    -To comply with a legal obligation and, in particular, to establish a verifiable consumer request
– Pro provide you the Service and in particular to provide assistance requested from our support service    You; directly or indirectly    -Business or persons providing services to us
-Public authorities
-Our affiliates
NB.  Choppinglife Player is present on Choppinglife digital properties and on third parties’ digital properties (ex. websites). When our Player is embedded on a third party’s website, we use, for technical reasons, the url of that website to deliver ads and Content. In general, urls do not reveal any of your SPI. In rare cases where full urls might suggest your SPI (ex. when you visit a website addressed to a religious community, its url may suggest your religious convictions), note that Choppinglife does not use that SPI. The full urls are used by us for technical purposes, including to display Content or ads, ensure security and debug, without the actual content of the url being analyzed by us.  

8.6.1.a.ii.2. Collected PI: Categories, the Purposes It is Sold or Shared for and the Categories of Third Parties Your PI is Sold to or Shared with
The CPRA defines the “Sale” of PI as sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s PI by the Business to a third party for monetary or other valuable consideration. When your PI is thus communicated for Cross-Context Behavioral Advertising, then such communication is referred  as Share.

The CPRA definitions of Sale and Share differ from the common understating of these terms. Note that although Choppinglife does Sell and Share your PI, we are not a data broker, which means that we do not sell data bases and instead, any disclosure of your PI is in relation with our business activity i.e. the operation an online service offering access to videos and displaying ads). Additionally, Choppinglife does not knowingly Sell or Share PI of minors under 16 years of age.

As a part of our business activity, we may Sell to and Share your PI with third parties with whom we cooperate, advertisers or tech companies. When you use our Service, our advertising partners collect your PI, such as digital identifiers (e.g. online identifiers, IP address), activity history (how you interact with their ads) and electronic information (e.g. what browser you use), and you are shown their ads. These companies may use such information to help us conduct our business activities (in doing so, they are our Service Providers) and for their own business purposes including tailoring ads you see on and outside of our Service. Targeting of ads based on your PI obtained from your activity across different businesses, distinctly-branded websites, applications, or services is referred to under the CPRA as “Cross-Context Behavioral Advertising”. When our advertising partners engage in Cross-Context Behavioral Advertising (i.e. when they use your PI collected on our Service and on other websites and services, to show you ads on and outside of the Choppinglife Service), our disclosure of your PI to them amounts to the Share of your PI.

Note that there is no Share of your PI when ads you see on our Service are targeted exclusively using the PI collected on the Choppinglife Service. Consequently, if you Opt-Out of Sale or Share of your PI, you will still see ads on our Services and these ads may continue to be tailored to your interests but that tailoring may be less precise as it will be based only on the PI collected while using the Choppinglife Service. Your PI may continue to be disclosed to other entities but they can use it only for Choppinglife’s business purposes and pursuant to a written contract we have with them.

If you are over 16 and wish to Opt-Out from the Sale or Share of your PI please refer to section 8.6.1.a.vi below to learn how to exercise that right.

The following categories of PI have been Sold or Shared by Choppinglife for the below-listed purposes in the preceding 12 months:

CATEGORY OF PI    EXAMPLES OF PI (DEPENDING ON THE PI YOU PROVIDE TO US AND YOUR USE OF OUR SERVICE)    BUSINESS OR COMMERCIAL PURPOSE THE PI IS SOLD OR SHARED    CATEGORIES OF THIRD PARTIES WITH WHOM PI MAY BE SOLD OR SHARED DURING THE PRECEDING 12-MONTH PERIOD
Identifiers    Unique digital identifiers linked to your device, browser or application (ex. Service ID, third party online identifiers, cookie IDs), IP address    To provide you the Service and achieve our business purposes including delivery of targeted ads    -Tech companies
-Advertising partners
Demographic Information    Age range, either deduced or actual gender, language, geographic location    To provide you the Service and achieve our business purposes including delivery of targeted ads    -Tech companies
-Advertising partners
Geolocation data    IP address    To provide you the Service and achieve our business purposes including delivery of targeted ads    -Tech companies
-Advertising partners
Device and connectivity information    Information about your current connection to the Choppinglife Service pertaining to the device and Service connection; device used, language and other settings, operating system browser, url    To provide you the Service and achieve our business purposes including delivery of targeted ads    -Tech companies
-Advertising partners
8.6.1.a.iii. Retention Period of PI
Your PI is retained for as long as it is needed to fulfill our business purposes, including the execution of a contract we have with you, compliance with legal obligations or as necessary for the establishment, exercise or defense of legal claims. It is deleted, aggregated, deidentified or anonymized once it is no longer needed for the purposes described above. For each type of data and operation, we set retention timeframes based on the purpose for its collection, and ensure it is kept for no longer than necessary.

8.6.1.a.iv. Automated Decision-Making
Choppinglife uses algorithms to improve our Service. For example, we use algorithms to generate more pertinent search results when you use our search engine. We also use them to infer some information from your use of our Service. That information may be your age range or gender. We use that deduced information to provide you with a more personalized experience.

8.6.1.a.v. California Consumer Rights
If you are a California resident, you have the right to know what PI we have collected about you, including the categories of PI, the categories of sources from which your PI is collected, the business or commercial purpose behind our collection Sell or Share of your PI, and the categories of third parties to whom your PI may be disclosed. You may request access to (including obtaining a portable-format copy of your PI that you provided to us) or deletion of your PI or correction of inaccurate PI that we have in our records and that we have collected or otherwise obtained during the 12-month period preceding your request. You also have the right to instruct us not to Sell or Share your PI with Third Parties and, to the extent that your SPI are used otherwise than to provide you with our Service or as authorized under the CPRA (which, at present Choppinglife does not do) to Limit the Use and Disclosure of SPI.

You may exercise any of these rights either directly or through an authorized representative. If you wish to make a request regarding your PI via an authorized agent, you must provide this agent with your written permission indicating the right which you wish to exercise, which is to be submitted to Choppinglife together with copies of your and your agent’s official IDs at the time of filing a request. We may ask for additional documents or information if we judge them necessary to establish whether your request meets the legal standards of a verified request (i.e. means to determine that the consumer making a request is the consumer about whom Choppinglife has collected PI, or if that consumer is less than 13 years of age, the consumer’s parent or legal guardian), verify the agent’s authority to act on your behalf, the extent of the authorizations you have granted and to identify your PI.

Your choice to exercise any of the above-listed rights will not result in any discriminatory treatment regardless of whether in relation to your use of the Choppinglife Service or Secondary Websites.

8.6.1.a.v.1. Right to Opt-Out from Sale or Share of Personal Information and Limit the Use and Disclosure of SPI
You have the right to “opt-out” of the Sale or Share of your PI, which means that you can tell a business to stop Selling or Sharing your PI and to refrain from Selling or Sharing it in the future. Exercising your Opt-Out right does not affect previously Sold or Shared PI.

To exercise this right, click on the “Do Not Sell My Personal Information or Share/Process It for Purpose of Targeted Ads” link available within this Privacy Policy and on our Service. If you access our Service through our Player embedded on third party websites or applications or while using a small-screen device, you may see a different link. For technical reasons, due the available space, you may see a shorter text such as “Don’t Sell/Share/use my Info for Targeted Ads” or “Opt-Out Sale/Share/Targeted Ads”.  

Note that the Opt-Out link may not be visible or functional if you access our Service using a non-California IP address (e.g. while accessing the Choppinglife Service from a different state or country or doing so using location-masking technologies such as a proxy or a VPN (Virtual Private Network) software). If you are a California resident and encounter problems in the exercise of your Opt-Out right, such as if you are not physically in California at the time, we invite you to contact us directly using either of the contact methods listed in Section 8.6.1.viii.

When available, you may also use a so-called “opt-out preference signal”, i.e. a browsing technology meeting the standards set by CPRA, that enables you to opt-out from Sale or Share of your PI with all businesses you interact with on-line using a given device and browser without having to exercise that choice individually with each of such businesses. Note that while we provide you with the possibility to opt out from our Sale and Share of your PI, the implementation of that opt-out preference signal may not be frictionless and require some additional interaction from you.

Upon exercising your right to Opt-Out, we will cease Selling and Sharing your PI. In particular, we will refrain from disclosing it to Third Parties for their own business purposes.

Note that while we will not Sell or Share your PI once you exercise your Opt-Out right, we may still disclose such information to our business partners in order for them to help us carry out our own business activities. In these circumstances, our business partners will act as our Service Providers or Contractors and they will not be allowed to use your PI for any purposes other than those we ask them to or as otherwise authorized by the CPRA.

We remind you that an Opt-Out decision is limited to the device and the browser used. If you use our Service on different devices or via different browsers, your Opt-Out decision needs to be communicated to us separately on each of them and renewed every time the associated Service ID is no longer active.

Additionally, if your Service ID is no longer recognized by our Service (either because the cookie it is stored in has expired or because you or the technology you use (e.g. your Internet browser) has deleted such cookie or prevented its deployment), we will no longer be capable of either recognizing you or acknowledging that you have opted-out from the sale of your PI. We invite you to verify your registered options by accessing your CCPA settings through the “Do Not Sell My Personal Information or Share/Process It for Purpose of Targeted Advertising” link (or “Don’t Sell/Share/use my Info for Targeted Ads” or “Opt-Out Sale/Share/Targeted Ads”) and to renew the Opt-Out procedure if needed.

Note that Choppinglife does not use SPI for purposes other than the ones disclosed in section  8.6.1.a.ii above or as otherwise permitted under the CPRA. Consequently we limit our use and disclosure of your SPI to what is necessary to perform the services reasonably expected by an average user of the Choppinglife Service or as otherwise authorized under the CPRA.

8.6.1.a.v.2. Requests to Opt-In After Opting-Out of the Sale and Share of Your PI
Once you have exercised your right to Opt-Out, it is possible for you to opt back into the Sale and Share of your PI. You will be alerted if a transaction requires the Sale of your PI in order to be completed.

Opting back into the Sale and Share of your PI is an easy two-step process: you just have to request to opt-in and you will then be asked to confirm your choice. You may do so by clicking the “Do Not Sell My Personal Information or Share/Process It for Purpose of Targeted Advertising” link (or “Don’t Sell/Share/use my Info for Targeted Ads” or “Opt-Out Sale/Share/Targeted Ads”) or by using any of the other contact methods described in Section 8.6.1.h below.

8.6.1.a.v.3. Right to Access and / or Delete Your PI and / or Correct Your Inaccurate PI
In addition to the right to be informed about the PI we collect, disclose, Share or Sell (i.e. information available in this Privacy Policy), you have the right to request that Choppinglife provides you with access to the specific pieces and categories of your PI that Choppinglife has collected, disclosed, Sold or Shared during at least  12 months preceding your request. This request can only be made once every 12 months.

You also have the right to request the correction or deletion of your PI that Choppinglife collected or maintained during the same 12-month period.

If requested so and to the extent technically feasible, upon receipt of your access request we will provide the specific pieces of PI obtained from you in a form that is easily understandable to the average consumer, in a structured, commonly used, machine-readable format enabling transmission to another entity without hindrance.

Upon receipt of your verifiable request to delete your PI, we will proceed with the deletion of such information unless otherwise authorized or required by law.

8.6.1.a.vi. Methods for Submitting a Verifiable Consumer Request
In addition to exercising your Opt-Out right via the “Do Not Sell My Personal Information or Share/Process It for Purpose of Targeted Advertising” link (or “Don’t Sell/Share/use my Info for Targeted Ads” or “Opt-Out Sale/Share/Targeted Ads”)available in the present Policy and on our Service, you may submit your Opt-Out, access, correction or deletion request by contacting our Support Policy Team using one of the following methods:

making a request via the “Personal Data” dedicated section available on the Choppinglife Help Center;
sending an email to feedback@Choppinglife.com
At a minimum, the following information must be provided with your request:

your account login (email address, username or other account credentials used to log-in to your Choppinglife account) or your Service ID(s), which you will be able to retrieve by following the instructions that we will provide to you;
the nature of your request, i.e. what rights you wish to exercise;
documents evidencing that you are a California resident;
an email or a physical address we may use for further correspondence in relation to your request;
whether your request concerns yourself or a third party (if you file on behalf of a third party, you must submit documents evidencing your legal authority to do so (e.g. a signed document from the person you file the request for specifying the content of the request you are authorized to file, together with a copy of that person’s and your own official IDs)).
To help our Help Center team identify the applicable procedures, we strongly recommend that you mention in the object or body of your request a reference to the CPRA or California Consumer Protection Act.

Depending on the content and circumstances of your request, you may need to follow additional procedures (e.g. retrieve your Service ID following the instructions provided by our Support Team) or provide additional supportive documents as necessary to confirm your identity and allow us to identify your PI. 

Note that in order to comply with requests to access, correct, delete, or disclose a consumer’s PI, it is mandatory for Choppinglife to first verify such requests. The CPRA rights in relation to your PI can only be exercised by you, meaning that your request cannot concern PI that is not yours and no one else can exercise the CPRA rights in relation to your PI (unless acting as your authorized agent). Consequently, before processing a request, we need to take reasonable measures to verify the identity of the person sending us a request, that person’s entitlement to exercise the CPRA rights and to identify the information such request relates to.

The actual verification process may take different forms depending on the circumstances of your request. For example, if you have a Choppinglife account, you may be asked to reply to a verification email sent to you by our Support Team at the email address you use to log-in. The Choppinglife Support Policy team will guide you through the applicable procedures.

Your requests will be answered within the CPRA-prescribed 45-day period. However, when reasonably necessary, we may require up to an additional 45 days to  respond to your request. We will inform you if we decide to extend the reply period.

8.6.1.b Third Party Marketing Activities
If you are a California resident, you may be entitled to request disclosure of the categories of PI (such as your name and contact information), if any, that we share with third parties who wish to contact you or send you promotional information about their products and services directly (as compared to when the third party is acting on our behalf or you have provided your PI as part of a co-promotion by Choppinglife and the third party). You may also request the names and addresses of these third parties. Please note that you can only make these requests once per calendar year.

If you are a California resident and would like to request a copy of this information regarding our disclosure of PI to third parties for their direct marketing purposes in the preceding calendar year, please contact us using the procedure described in Section 8.6.1.a. (viii). or send us a letter at: Legal Department, Choppinglife Inc., 57 East 11th Street, 5th Floor, New York, NY 10003, United States.

8.6.1.c. Specific Rules Applicable to Deletion of Information Published by Minors
If you are a California resident under the age of 18 and a registered user of the Choppinglife Service, you may request and obtain removal of Content or information that you have posted publicly on the Choppinglife Service. To make this request, please contact the Choppinglife Help Center and include a detailed description of the specific content or information you would like to remove and confirming your country and state of residence. Please note that this removal does not ensure complete or comprehensive removal of the Content or information posted on the Choppinglife Service by you, as there may be circumstances in which the law does not require or allow removal.

9. SPECIFIC CONDITIONS APPLICABLE TO Choppinglife SECONDARY SITES
   In connection with its main activity as a content hosting platform, Choppinglife operates Secondary Sites addressed to professionals in the advertising industry, such as software developers wanting to contribute to or use the Choppinglife APIs, content right holders interested in the Choppinglife’s Partner Program, advertisers, media agencies and various actors of the marketing sector and other persons who wish to learn more about our offering and our company of apply for a job position. All of the Secondary Sites can be accessed from the Choppinglife Site but, due to the particularity of their audience, may be subject to distinct terms of use.

Indeed, since the Secondary Sites of Choppinglife are not intended primarily for users of the Choppinglife Site, the Processing purposes described in this Privacy Policy are not the same as those applicable to the Secondary Sites.

The Secondary Sites may collect their visitors’ Data for purely statistical purposes, in particular to register the number of visits to the Secondary Sites’ pages and the behavior of their visitors (e.g. navigation time, pages clicked on, videos viewed, or articles read, etc.).

Choppinglife may use different types of cookies on the Secondary Sites:

so-called “functional” cookies designed solely to operate these Secondary Sites correctly or, if you decide so, to enable you to log-in using third party log-in tools (e.g. Facebook Connect);
audience measurement and statistical analysis cookies, deposited by Choppinglife or by our subcontractors providing audience measurement services (e.g. Amplitude).
The use of these audience measurement cookies is subject to the same rules as those explained in the present Privacy Policy. You can, at any time, oppose their use by indicating your decision on the Consent Management page accessible from the footers of our Secondary Sites. You may also exercise your rights of access, modification or deletion as described in Section 8 above.

10. International Data Transfers and Standard Contractual Clauses
    When storing your Data Choppinglife uses its own servers as well as those of its service providers including cloud storage service providers. Choppinglife’s policy is to use servers located in Europe, whenever technically possible.  

Choppinglife Service data is stored on servers owned by Choppinglife and located in France. In order to maintain a uniform, world-wide quality and availability of the Choppinglife Service throughout the world and to protect against data loss, we duplicate part of the data stored on our EEA-based servers  and on other servers owned and operated by us and located outside the EEA, currently in the USA and in Singapore.

Choppinglife respects privacy rights, and strives to collect, use and disclose your Data strictly as necessary and in a manner consistent with the applicable laws, including when such processing of your Data is carried out outside of the country of your residence. We may disclose your Data to third parties, be it our service providers, our Commercial Partners or public authorities, including those located outside of your country of residence.

In particular, Choppinglife transfers the Data of EEA residents to non-EEA countries, only when sufficient level of protection is ensured.

Note that the competent European Union authorities have determined a list of non-EEA countries considered as providing an adequate level of protection. Transfer of Personal Data to such countries does not require additional safeguards. When transfer of EEA residents Data by Choppinglife is undertaken to countries that are not on this list and is not otherwise authorized by the applicable laws, such transfer relies on the  following mechanisms  to ensure the security of your Data:

the conclusion of Standard Contractual Clauses approved by the European Commission, which may be found at the following URL: European Commission Standard Contractual Clauses, or
the existence of approved Binding Corporate Rules in place within multinational organizations aiming at ensuring that any transfer of Personal Data from the EEA to their non-EEA affiliates does respect adequate safeguards for protecting Personal Data throughout the organization.

11. MISCELLANEOUS
    11.1. Third-Party Access Points, Devices and Links
    The Choppinglife Service may be accessible through third-party websites, applications and other means of access operated by other companies (collectively, “Third-Party Access Points“). For example, you can access the Choppinglife Service through third-party websites where the Video Player has been embedded. The Choppinglife Service also may contain links to third-party websites or applications. For example, if you click on an advertisement or a search result on our website, you may be taken to a website that we do not control. None of these Third-Party Access Points, devices, websites or applications are operated by Choppinglife, even if they contain our name or logo. As such, we are not responsible for the privacy practices of the operators of these Third-Party Access Points. Accordingly, we recommend that you review their respective privacy policies for further information.

11.2. Deleting Your Choppinglife Account
If you have an account with us, you may choose to delete your Choppinglife account, in accordance with our Terms of Use , via the settings of your Choppinglife account when signed in. If you are a Member of our Partner Program, deletion of your account will require a prior termination of that Program. Please note that after you delete your account, you will not be able to sign into our website or access any of your Personal Data. However, you can open a new account at any time. If you delete your account, we will still retain some information from or about you when we are required to do so under the applicable law or contracts we are party to. We may also continue to use some of the Data in anonymized or pseudonymized forms for various operational and analytical purposes. In addition, if certain information has already been provided to third parties, as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

11.3. Applicable Law and Jurisdiction
If you reside in a country of the European Economic Area, UK and Switzerland: unless the waiver of choice of jurisdiction is not authorized under applicable laws, you agree that any dispute between you and Choppinglife arising out of or relating in any way to this Privacy Policy or our collection, processing and/or use of your Data shall be interpreted in accordance with the laws of Nigeria, without reference to its conflicts of laws, and notwithstanding multiple defendants or third party claims. You also agree that any claim or dispute between you and Choppinglife shall be decided by a court of competent jurisdiction located in Lagos. 
If you reside in a country that is not part of the European Economic Area, UK or Switzerland: unless the waiver of choice of jurisdiction is not authorized under applicable laws, you agree that any dispute between you and Choppinglife arising out of or relating in any way to this Privacy Policy or our collection, processing and/or use of your Data shall be interpreted in accordance with the laws of the Lagos, Nigeria, without reference to its conflicts of laws, and notwithstanding multiple defendants or third party claims. You also agree that any claim or dispute between you and Choppinglife shall be decided by a court of competent jurisdiction located in the Lagos.

 
11.4. Changes to this Privacy Policy
From time to time, we may revise this Privacy Policy to reflect changes in the law or the Choppinglife Service or for other reasons in our discretion. We may do so as needed, but in any event, the Privacy Policy will be updated at least once every 12 months. Therefore, it is important that you verify the effective date of the latest update of the Privacy Policy each time you visit the Choppinglife Site or use any of the Choppinglife Service, to ensure you are familiar with our most updated policies and practices. If we make any material change to this Privacy Policy, we will notify you by posting a notice on the Choppinglife Site.

 If you are a User or a Partner, we may also send an email to the email address that you most recently provided to us in your Choppinglife account settings, prior to the material change taking effect. Accordingly, please keep your account information, including email address, updated. Any material change to this Privacy Policy will be effective automatically (i) 7 days after the revised Privacy Policy is first posted or, for users who register or otherwise provide opt-in consent during this 7-day period, at the time of registration or consent, as applicable, or (ii) immediately upon its publication, if required so by applicable laws.

11.5. Contact Us
If you have further questions about this Privacy Policy, wish to learn more about our information-handling practices, or wish to exercise your Privacy Rights, you can reach us:

by sending an email request to the Choppinglife Help Center via the dedicated “Your Personal Data” section or to the domestic representative designated below, if he/she is located in your country or state of residence,
To help our Help Center team identify the applicable procedures, we strongly recommend that you mention in the object or body of your request a reference to the local privacy law you refer to (e.g. GDPR, CCPA) and identify yourself as well as your country of residence.

by sending a letter to the attention of:
our Data Protection Officer at the following address: Souljar Mind Entertainment Network 26, HoLY Mary  Street, Otta Ogun State Nigeria.

Postal Address: Souljar Mind Entertainment Network, Holy Mary Street, Ota Ogun Nigeria
Email: info@choppinglife.com

In case of translation of all or part of this Privacy Policy, you acknowledge and agree that only the English version of this Privacy Policy shall prevail in any event, including where such translation is provided by Choppinglife.