1.    Introduction

We are delighted that you are concerned about your privacy rights and have shown an interest in our data protection practices. We are committed to safeguarding the privacy of our service users, customers, partners, their respective individual end users who interact with Vuukle’s offerings, and individual end users of this website.

We are an audience engagement and ad revenue monetization platform. We provide web-based products and services to owners and administrators (“Publishers”) of websites, mobile apps, and other internet connected properties (“Publisher Properties”) to improve their audience engagement and ad revenues. These products and services are: 

●      Quizzly.AI related offerings for doing brand-lift surveys, undertaking user research, targeting advertisements basis user preferences, customer leads generation, and serving real-time advertisements basis user responses;

●      Social Share Bar Widget and associated services;

●      Comments Widget and associated services;

●      Reactions Widget and associated services;

●      Audience and Revenue analytics;

●      Targeted and non-targeted online advertising.

(collectively, “Vuukle Services”)

In this policy, we have set out how we process data relating to individuals interacting with Vuukle Services. We process this data from individual end users of our websites, individual end users of Publisher Properties using Vuukle Services, and Vuukle’s partners (“Privacy Policy”). This Privacy Policy is applicable to all Vuukle Services. These may either be offered by Vuukle DMCC (incorporated in the United Arab Emirates). Vuukle DMCC is the sole controller and operator of the Vuukle Services.

Vuukle DMCC (referred to as “Vuukle”) collects and processes data in accordance with the relevant applicable privacy laws. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, you should not use our website. Publishers accept, agree, and understand the terms of this Privacy Policy in entering into an agreement with Vuukle. Publishers also ensure that their end users agree to this Privacy Policy, wherever required. By using and/or accessing our website, authenticating yourself in accessing any of the Vuukle Services on Publisher Properties, or otherwise providing us with your data wherever a link to this Privacy Policy is displayed, you acknowledge that you have read, understood, and agreed to this Privacy Policy and our Terms and Conditions. 

This Privacy Policy does not apply to personal information we collect and process from our employees, contractors, or job applicants in their capacity as employees, contractors or candidates.

2.    Vuukle Services and User Data

Vuukle collects certain types of information from end users on its website(s) and on Publisher Properties using Vuukle Services. This information is called “User Data”. This User Data is integral for Vuukle to effectively provide Vuukle Services to Publishers. Vuukle uses User Data for delivering Vuukle Services in two ways:

A.    Where Publishers want to use Vuukle Services to improves their users’ engagement, Vuukle Services collects and provides User Data to Vuukle’s Demand Partners who help deliver personalised ads and engagement content on Vuukle widgets integrated on Publisher Properties. 

B.    Where Publishers only want to monitor their audience’s engagement on Publisher Properties, Vuukle Services collect and provide the User Data to Publishers themselves for this purpose.

For avoidance of doubts, “Demand Partners” refer to advertisers and associated marketing service providers, including, vendors and their partners or affiliated entities who:

o   target advertising for products and services by various companies;

o   facilitate the operations of targeted advertising by providing analytics, traffic, fraud detection, and ad quality verification services;

o   market products and services through advertising;

o   seek to understand their marketing efforts, reach, and customer perception for their products and services;

o   seek to gauge, generate, or measure audience interest for their existing or upcoming products and services;

o   seek to understand customer preferences, behaviours, and interests for the purposes of research, marketing, or otherwise; and

o   seek to understand audience/customer interests, preferences, behaviours and interests for their products and services.  

For Vuukle’s Demand Partners, the User Data is important as it allows them to optimise (for themselves and their partners) their respective advertising spends by reaching the right users, measure the effectiveness of their marketing campaigns, and understand customer preferences, interests, and behaviours

Note, only in limited circumstances discussed in Section 8 below, the User Data collected by Vuukle can identify an individual in real life, and therefore, amount to Personal Data. Vuukle is not an ad network, a media buyer or seller, or a data broker. We do not own digital properties on which we enable advertising.

3.    What comprises ‘User Data’?

As discussed above, Vuukle Services collects User Data from end users using its website(s) and Publisher Properties using Vuukle Services. As applicable and appropriate, this User Data may contain the following types of information:

(i)             Collected Data: This is information collected by Vuukle Services from users accessing the Vuukle website(s) and Publisher Properties using Vuukle Services. This includes such information as: Digital Identifiers and Privacy Choices (see definitions for both in Section 5 below), device or browser language, device make and model, the broad geolocation of a user’s device, and finally, Usage Information of Vuukle Services not requiring Authentication. The ‘Usage Information of Vuukle Services not requiring Authentication’ includes the user’s interaction with Vuukle Services including use of reaction function, social share function, clicks on ads displayed as part of Vuukle Services, responses on Quizzly.AI widget for quiz questions recording the user’s interests, preferences, habits, and choices; 

(ii)            Authenticated User Data: This is information directly provided by the users after authentication on Vuukle website or in accessing certain features of Vuukle Services on Publisher Properties which require their authentication. The users provide this information after agreeing to Vuukle Terms and Conditions and this Privacy Policy. This information typically includes the user’s name, email address, IP address, account preferences and settings, and Usage Information from Vuukle Services requiring authentication. The Usage Information of Vuukle Services requiring authentication includes comments posted by a user on Publisher Properties and responses to quiz questions on Quizzly.AI recording that user’s interests, preferences, habits, choices, and.

(iii)           Leads Data: This is information directly provided by the users by agreeing to fill a form or otherwise while interacting with specific Vuukle Services on Publisher Properties. For instance, Quizzly.AI widget users on Publisher Properties may be given an option during a marketing campaign to provide their information in a form. The users provide this information after agreeing to Vuukle Terms and Conditions and this Privacy Policy. This information typically includes name, email, and phone number of users. 

Unless specified otherwise, any references to data or information in this Privacy Policy should be construed as a reference to User Data. 

4.    What do we mean by Client Data?

Publishers who use Vuukle Services on their Publisher Properties use them pursuant to establishing a commercial relationship with Vuukle. When Publishers and Vuukle enter into such a relationship, the Publishers register an account with Vuukle. For this account registration, Publishers consent to provide their own information to avail Vuukle Services. This information typically includes the Publisher’s name, username, email, the details of their Publisher Properties, billing information (address, tax details, and bank account information), and/or similar information of their relevant employee or agent. Once the account of a Publisher is set up on Vuukle, we also collect the Publisher’s account information and settings.

There are various Publishers who approach Vuukle with inquiries to avail Vuukle Services for their respective Publisher Properties. Vuukle collects the information of such Publishers from forms on its website, phone calls, emails, or by creating a Publisher account on Vuukle’s website. This information typically includes the Publisher’s name, username, email, the details of their Publisher Properties, billing information (address, tax details, and bank account information), any queries, and/or similar information of their relevant employee or agent. These Publishers provide their information to Vuukle with their consent after agreeing to Vuukle’s Terms and Conditions and Privacy Policy through the form on Vuukle website or during account registration. In case of emails and phones, Vuukle notifies the Publishers that their data shall be collected in accordance with this Privacy Policy.

This data and information of partner Publishers and Publishers making inquiries is referred to as “Client Data” throughout this Privacy Policy.

5.    Glossary of certain terms

Cookie: A cookie is a small text file that is stored in a web browser by a website or Ad Server. By saving information in a cookie, websites and servers can remember preferences of users. Similarly, by placing a unique cookie containing a unique code on a user’s browser (“Cookie ID”), the visits of a user and their interactions with websites across visits can be mapped. Therefore, aiding identification of a user. Cookie IDs are Digital Identifiers.

Digital Identifiers: When a user first visits a Publisher Property that has integrated Vuukle Services or Vuukle’s own website, this triggers Vuukle to place a unique digital identifier on the user’s browser or mobile device. These random unique identifiers are cookies and mobile advertising identifiers. We collect these identifiers from users to recognize the user’s browser or device the next time it visits the same or another Publisher Property having Vuukle Services integrated in it. We also collect these identifiers to connect the users to their other Collected Data and/or Authenticated User Data (wherever available).

Mobile Advertising Identifiers: Mobile advertising identifiers (e.g., Apple's iOS Identifier for Advertising (IDFA) or Google's Android Advertising ID (AAID)) are unique IDs that are similar to cookies, but, instead of being stored on your web browser, are associated with individual mobile devices. They usually are user-resettable. Like other Digital Identifiers, Mobile advertising identifiers do not tell us who an Internet user is in the "real world", but may, when combined with other information, allow the identification of an individual. Mobile advertising identifiers are used in connection with apps on your mobile device as opposed to websites that you access through a browser.

Privacy Choices: Privacy Choices refers to users’ consent for processing of their data recorded directly through Vuukle’s consent box, through the Publisher’s Consent Management Platform (“CMP”) tool, or any other mechanism. These are recorded through cookies placed on the user’s device when the user consents to processing of their data. Where the consent of the user is not received for processing of their data, Vuukle neither places any cookies on the user’s browser nor collects any Collected Data from such users.

6.    What information do we collect and how?

Vuukle Services are designed to collect and use only User Data (i.e., Collected Data, Authenticated User Data, Leads Data, and Digital Identifiers) as described in this Privacy Policy.

The different types of User Data is collected as per the mechanism below: 

(i) Collected Data: Vuukle Services collect this User Data using Digital Identifiers associated with particular web browsers or devices. Note, Publishers and Demand Partners, and their respective third-party clients and vendors, may use their own Digital Identifiers. We are not responsible for their privacy practices, including their collection, use, and/or sharing of data and/or their use of technology on the Publisher Properties or in their advertisements.

(ii) Authenticated User Data: Vuukle Services rely on users themselves to provide this information which is collected by Vuukle as Authenticated User Data:

- The users may choose to provide this information when prompted in accessing certain features on Publisher Properties enabled by Vuukle which require user authentication. For instance, on Publisher Properties that use Vuukle’s comments widget, users of Publisher Properties are required to provide their authentication information. 

- The users may also choose to provide this information when using certain optional features on Vuukle Services integrated on Publisher Properties. For instance, on Publisher Properties that have Quizzly.AI widget integrated, users of Publisher Properties may authenticate themselves and create an account to know their quiz scores, leader board positions, performance assessments, and other game features related to quizzes.

(iii) Leads Data: Vuukle Services rely on users themselves to provide this information which is collected as Leads Data. Users accessing Publisher Properties may choose to provide this information while interacting with Vuukle Services integrated on Publisher Properties. For instance, on Publisher Properties that have the Quizzly.AI widget integrated, users of Publisher Properties may participate in a quiz and indicate their interests for products and services and consent to provide their information for further marketing and communication.

Vuukle collects Client Data as described in this Privacy Policy. For onboarded Publishers, the Client Data is provided by the Publishers at the time of entering into a contract with Vuukle and during the registration of their account with Vuukle. For Publishers inquiring about Vuukle Services, the Client Data is provided by the Publishers in the forms filled by them on Vuukle website or during account registration. Publishers also provide their data through emails and phone calls.

7.    Why and how do we use the information we collect?

As discussed in Section 2, Vuukle Services collect User Data to accomplish the goals of its partner Publishers and Demand Partners. 

Use of information

Accordingly, the different types of User Data is collected for the purposes described below:

(i)  Collected Data: 

- To create user profiles for personalised advertising;

- To develop and improve Vuukle Services;

- To understand audience/customer interests, behaviours and preferences for specific products and services, brands, or otherwise;

- To measure advertising performance;

- To measure performance of marketing activities of brands or their different products and services through quiz surveys deployed as part of Vuukle Services;

- To measure performance of Vuukle Services;

- To understand audiences through statistics or combinations of data from different sources;

- To use limited data to select advertising;

- To use profiles to select personalised advertising; and

- To use profiles to select personalised content.

(ii) Authenticated User Data:

- To create user profiles for personalised advertising;

- To comply with laws regarding hate speech, obscene language, etc.;

- To provide enhanced engagement with Publisher Properties;

- To develop and improve Vuukle Services;

- To understand audience/customer interests, behaviours and preferences for specific products and services, brands, or otherwise;

- To measure advertising performance;

- To measure performance of marketing activities of brands or their different products and services through quiz surveys deployed as part of Vuukle Services;

- To measure performance of Vuukle Services;

- To understand audiences through statistics or combinations of data from different sources;

- To use limited data to select advertising;

- To use profiles to select personalised advertising; and

- To use profiles to select personalised content.

(iii) Leads Data:

- To enable personalised advertising and marketing

- To understand audience/customer interests, behaviours and preferences for specific products and services, brands, or otherwise;

- To understand audiences through statistics or combinations of data from different sources;

- To use limited data to select advertising;

- To use profiles to select personalised advertising; and

- To use profiles to select personalised content. 

Sharing of Information

In fulfilment of the above purposes, the User Data collected by Vuukle is shared with Vuukle’s partner Publishers and Demand Partners as discussed in Section 2. These Publishers and Demand Partners include entities:

·       enabling targeted advertising to users;

·       facilitating the functions of Demand Partners (including, traffic, fraud, and ad quality verification vendors);

·       providing analytics to the Publishers;

·       marketing products and services through advertising;

·       seeking to understand their marketing efforts, reach, and customer perception for their products and services;

·       seeking to gauge, generate, or measure audience interest for their existing or upcoming products and services;

·       seeking to understand customer preferences, behaviours, and interests for the purposes of research, marketing, or otherwise;

·       seeking to understand audience/customer interests, preferences, behaviours and interests for their products and services.

Vuukle uses Client Data for the purposes of successfully integrating Vuukle Services on Publisher Properties, to allow the Publisher to operate their account effectively, to allow the Publisher to monitor performance of Vuukle Services on Publisher Properties, and to allow the Publisher to comply with laws regarding speech on their Publisher Properties. We do not share Client Data with other entities.  

Even when a Publisher no longer uses Vuukle Services, we may continue to use and share the User Data associated with their Publisher Properties and their Client Data as collected in accordance with this Privacy Policy. We may also share the User Data with third parties in the following circumstances:

(a)   Pursuant to a request or authorization by an user or a Publisher if the disclosure is provided to: 

                i.         comply in good faith with applicable laws, rules, regulations, governmental and quasi-governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; 

              ii.         enforce our terms and conditions or other agreements; or 

             iii.         protect our, or any other person’s or entity’s, interests, rights, property, or safety, or in connection with an investigation of suspected or actual unlawful activity;

(b)   Upon processing it in a manner where it no longer can be deemed Personal Data either through aggregation or otherwise.

(c)   As part of a business purchase, sale, merger, consolidation, investment, change in control, transfer of all or substantially all of our assets, reorganization or liquidation, bankruptcy, or in connection with steps taken in anticipation of such an event (e.g. due diligence).

8.    Personal Data: A rationalised compliance with global privacy and data protection laws 

Vuukle does business on a global scale, and as such, we are required to meet the demands of privacy regulations and laws of many countries. At a high level, most data privacy legislation imposes many of the same types of obligations on organisations, and much of this regulation requires organisations to offer similar types of rights to individuals. With that in mind, our data governance program and as a result this Privacy Policy adopts a rationalized approach. We apply the strictest standards to meet the requirements of different privacy regulations around the world when seeking a solution to a privacy issue, or providing data subject rights, provided it does not violate any data privacy laws. Accordingly, this section discusses how Vuukle complies with various privacy regulations applicable. 

8.1  Elements of User Data and Client Data which are Personal Data

Under GDPR, "Personal Data" means any data relating to an individual who can be identified, directly or indirectly, from that data. It can take the form of a name, email, address, and can also extend to unique identifiers that do not tell who an Internet user is in the real world but may, when combined with other information, allow the identification of an individual. This is also largely consistent with the definition of Personal Data as per legislations in other jurisdictions including certain US States and India.

Amongst the User Data and Client Data collected by Vuukle, the following amounts to Personal Data:

·       Digital Identifiers in Collected Data: Overall, Collected Data does not allow Vuukle to identify an individual in the real world through their name, address, phone number, email address, or government identifier. Therefore, the different information collected by Vuukle as Collected Data does not strictly amount to Personal Data. Yet, Vuukle can use the Digital Identifiers collected as part of Collected Data to recognise a specific device or browser. As a result, Digital Identifiers are considered Personal Data. They are also recognised as such under the GDPR. 

·       Authenticated User Data: As the users provide their name, email address, and Vuukle collects the IP Address and Usage Data of such users providing their data, Authenticated User Data amounts to Personal Data under the GDPR. It also meets the definition of Personal Data as per legislations in other jurisdictions including certain US States and India.

In addition, access to quizzly.ai/play may require users to complete Face ID verification, which involves processing biometric data to securely verify identity. This may also include estimated demographic attributes such as age range and gender. Such biometric data is considered Personal Data under GDPR and other applicable privacy laws.

·       Leads Data: As the users provide their name, email address, and phone number, Leads Data amounts to Personal Data under the GDPR. It also meets the definition of Personal Data as per legislations in other jurisdictions including certain US States and India. 

·       Client Data: As the Publishers provide their name, username, email, the details of their Publisher Properties, and billing information (address, tax details, and bank account information), and/or similar information of their relevant employee or agent, Client Data amounts to Personal Data under the GDPR.

8.2  Collection of Personal Data, its use and sharing, and the purposes 

For the purposes of compliance with global privacy regulations, we confirm that the User Data that amounts to Personal Data as above is collected as prescribed in Section 6, and used for the purposes and shared accordingly as prescribed in Section 7. The use and sharing prescribed in Section 7 of this Privacy Policy could amount to ‘sale’ or ‘sharing’ of personal data under the California Consumer Privacy Act (“CCPA”) and similar relevant laws of other US states. 

Vuukle does not knowingly collect, use, or disclose sensitive Personal Data through our Vuukle Services. Vuukle does not target and does not partner with Publishers who target children under 16 years of age. Therefore, Vuukle does not knowingly collect, use, or share information pertaining to children under 16 years of age.

EEA and UK Data Subjects: Lawful basis for processing

For the data subjects based in the EEA and UK, Vuukle confirms that the User Data collected by Vuukle that amounts to Personal Data is:

·       collected by Vuukle through the mechanism prescribed in Section 6; and

·       used for the purposes and shared accordingly as prescribed in Section 7.

The lawful basis for Vuukle to undertake this processing for EEA and UK data subjects is as follows:

(i)             Collected Data:

·       Compliance with Legal Obligations: For compliance with Vuukle’s obligations under global data protection laws, Vuukle collects the users Privacy Choices. Wherever required under law or industry best-practice, Vuukle directly or indirectly via the Publisher’s CMP tool obtains consent of the users before collecting other elements of Collected Data.

·       Consent: Vuukle collects and processes the Collected Data after obtaining the data subject’s consent. This consent is either obtained through the Publisher’s CMP tool or by Vuukle directly on its widgets. Note, unless a data subject of the EEA provides their consent for processing of their data through the above mechanisms, Vuukle does not collect or process any Collected Data of such a user.  

·       Legitimate Interests: Some of the Collected Data is processed to improve the functionality of Vuukle Services and their integration on Publisher Properties.

(ii)            Authenticated User Data:

·       Compliance with Legal Obligations: For compliance with Vuukle’s obligations under global hate speech, defamation, and other speech-related rules and regulations, Vuukle collects the IP Address, Name, and Email address as part of the Authenticated User Data to ensure Vuukle and the Publisher partner can perform its legal obligations.

·       Consent: Vuukle collects and processes the Authorised User Data after obtaining the data subject’s consent during the authentication process. This consent is explicitly obtained during authentication and a link is provided to this Privacy Policy.

·       Contract: Vuukle processes certain Authorised User Data due to the contract entered into with the authenticated users in delivering them enhanced features of Vuukle Services. This includes engagement through competing with other players in quizzes and other related features.

(iii)           Leads Data:

·       Consent: Vuukle collects and processes the Leads Data after obtaining the data subject’s consent during the process where the relevant users provide their information which is collected as Leads Data. This consent is explicitly obtained in the collection of the information along with a link to this Privacy Policy.

(iv)           Client Data:

·       Compliance with Legal Obligations: For compliance with Vuukle’s obligations under data protection law, tax law, and other similar obligations, Vuukle collects and processes the Client Data.

·       Consent: Vuukle collects and processes the Client after obtaining the client’s (data subject’s) consent during the creation of their account on Vuukle website. This consent is explicitly obtained during account creation and a link is provided to this Privacy Policy. 

·       Contract: Vuukle processes certain Client Data due to the contract entered into with the its clients in delivering them Vuukle Services

8.3  EU & UK GDPR Roles and Vuukle

The EU & UK GDPR distinguishes between organizations that define the purpose and means of processing Personal Data (“Data Controllers”) and those organizations that only process the Personal Data on behalf of these data controllers (“data processors”). It is the data controllers who hold primary responsibility for your Personal Data. The User Data specified in Section 6 of this Privacy Policy is only collected, and therefore, only processed by Vuukle. 

Depending on the type of User Data, the purposes of processing this data may or may not be controlled by Vuukle. Therefore, Vuukle may or may not be Data Controller with respect to all the User Data collected as discussed in Section 6. Depending on the kind of Vuukle Services used on Publisher Properties, Vuukle may act as either a data controller or a data processor in handling your Personal Data. For instance, the Users are the data controllers for the account data pertaining to the accounts created by them with Vuukle upon authentication. Similarly, Vuukle is not a Data Controller of the Leads Data collected by Vuukle for its Demand Partners. But, it processes it to disseminate it to its Demand Partners for whom it is useful for marketing to such users. As for Client Data, Vuukle is a Data Controller.

8.4  Transfers of Data

All User Data and Client Data is stored on our secure servers. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, loss or damage.

Wherever Publishers enter into a contract with Vuukle Ltd (company registered in England & Wales) to use Vuukle Services on Publisher Properties, we try to only process your information within the UK and European Economic Area (EEA). If we or our service providers transfer personal data outside of the UK or EEA, we always require that at least one of the following safeguards are in place to protect the information when it is processed:

·       the destination country is deemed by the ICO or the European Commission to have an adequate protection for personal data;

·       an International Data Transfer Agreement or Addendum as specified by the ICO, or the standard contractual clauses specified by the European Commission, along with the supporting adequate supplementary measures wherever required basis our transfer impact assessments.

Wherever Publishers enter into a contract with Vuukle DMCC, Vuukle undertakes processing of your data in Singapore. For EEA and UK data subjects, we ensure that all data transfers happen in accordance with Article 46 of the GDPR and ensure that an International Data Transfer Agreement or Addendum as specified by the ICO is in place, or the standard contractual clauses specified by the European Commission is in place, along with the supporting adequate supplementary measures wherever required basis our transfer impact assessments.

9.    How is information stored, and How long is it kept?

Vuukle uses generally accepted industry security standards to protect User Data and Client Data transmitted through Vuukle Services, and stored for Vuukle Services. Vuukle does a regular review of our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We also restrict access to information to employees, contractors and agents who need the information in order to process it for us. Our employees, contractors, and agents are subject to strict contractual confidentiality obligations and may be disciplined, terminated, and sued if they fail to meet these obligations.

Please note, however, that no transmission or storage of information can ever be guaranteed to be completely secure. Once we receive User Data and Client, we will use strict procedures and security features to try to prevent unauthorized access. Please also be mindful that we are not responsible for the security measures of third parties.

We never store any User Data and Client Data longer than we need it. As far as possible, Vuukle also anonymises the User Data with unique serial numbers or hashes wherever the User Data contains any Personal Data as discussed in Section 8. This is done in furtherance of our commitment to data safety of users and to prevent any personal data leaks in the event of a data breach. When we no longer need the User Data, it is deleted or aggregated. Aggregated anonymized information is used for reporting and analysis, and may be stored in the our servers indefinitely.

When Demand Partners receive information through us, their storage and retention of the removed information is governed by their own privacy policies and applicable laws, rules, and/or regulations.

10. What Are Your Choices?

10.1 For European Data Subjects: IAB’s TCF

We are registered as a vendor with, support, and encourage our clients to use, the Transparency Consent Framework (“TCF”), which is designed to provide European Jurisdiction data subjects with dynamic transparency into and choice about the various third parties used on Digital Properties on which the TCF Framework is utilized. If you are a European Jurisdiction data subject, the TCF Framework is designed to enable Digital Properties – which may include our clients – to (i) choose which third parties (which may include Vuukle Services) they wish to allow to access your device and collect, use and share your personal data and (ii) provide dynamic transparency and choice to you about each of these third parties (e.g., an opportunity for you to consent) in connection with such Digital Property, depending on that third-party's use of your Personal Data and legal basis for such usage.

10.2 Do not sell or share your personal data

All users who have interacted with Vuukle Services have the right to opt out of the sale or sharing of your personal information. If you wish to opt out of the sale or sharing of your personal information, please click the link “Do Not Sell or Share My Personal Information” in the footer of our website(s) to record your preference. We will use the information you provide to handle your inquiry and keep a record of both your request and our corresponding response.

10.3 Managing your cookies

A majority of User Data collected and processed by Vuukle is Collected Data. As noted in Section 8, Collected Data has the potential to be Personal Data only due to Device Identifiers collected as part of User Data. Vuukle uses Cookie IDs and Mobile Advertising Identifiers as Device Identifiers. As discussed in Section 5, Cookie IDs and Mobile Advertising Identifiers are collected from the cookies stored on a user’s browsers and devices.

If a user wants to opt-out of Vuukle processing your Collected Data, you can delete cookies or Mobile Advertising Identifiers relating to Vuukle. This will disassociate further processing of information against your existing Cookie ID. This will also prevent Vuukle and our Demand Partners from being able to trace you for the purpose of any Vuukle Services or any other personalised content and ads. You will be treated by Vuukle as a first-time visitor the next time you visit the Vuukle website(s) and Publisher Properties using Vuukle Services.

For more information on managing your cookies can be found here:

https://allaboutcookies.org/how-to-clear-cookies

11. European Jurisdiction Data Subject Rights

If you are a data subject of a European Jurisdiction, you have certain rights and protections under the law regarding the collection, processing, and use of information about you. As stated above, the information we collect about you when you visit our website or Publisher Properties that use Vuukle Services may collect a user’s "Personal Data" as per the GDPR.

If you are a data subject of a European Jurisdiction and certain requirements are fulfilled and/or under certain circumstances, you have the right: (i) to access and obtain a copy of your Personal Data; (ii) to erasure of your Personal Data; (iii) to rectification or updating of your Personal Data; (iv) to object to the processing of your Personal Data; (v) to restrict the processing of your Personal Data; and (vi) to data portability (i.e., to be provided with a copy of your Personal Data in a structured, commonly-used, and machine-readable format, and/or to have such a copy provided to a third party). 

If you are interested in exercising any of these rights, you may do so via Prighter at this link: https://prighter.com/q/12424951778. Prighter is our GDPR Representative appointed in compliance with Article 27 of the GDPR. For residents of the UK, you can email your requests at privacy@vuukle.com. 

In addition, you also have the right to withdraw your consent at any time. If you wish to exercise such right with respect to interest-based advertising, you can do so through the mechanisms and methods set forth above under Section 10.

Vuukle ensures collection of a minimum amount of Personal Data about you that we believe is necessary to provide our products and services. Most of the information collected by Vuukle is not collected in a manner that it can identify an individual. Therefore, sometimes it is not feasible for us to provide individuals with information that is tied to their identities.

In accordance with the GDPR, you have the right to lodge complaints with respect to our processing of your data. For the users connected with EEA, you should lodge any such complaints with our representative Prighter at https://prighter.com/q/12424951778, or at privacy@vuukle.com. In circumstances where our Publishers enter into a contract with Vuukle Ltd (a company registered in England & Wales) for Vuukle Services, our Data Protection Officer will handle your complaints. You can email your complaints to privacy@vuukle.com.

If you are a resident of the EEA or the UK and you are dissatisfied with how we have managed a complaint you have submitted to us, you are entitled to contact your local data protection supervisory authority.

12. Your Rights under Certain U.S. State General Privacy Laws

If you are a resident of a U.S. state with an effective general privacy law (such as California under the California Consumer Privacy Act, including as amended by the California Privacy Rights Act (as amended, "CCPA"), and Virginia under the Virginia Consumer Data Protection Act) (each such law, a "US State Privacy Law"), you have some or all of the following rights with respect to your Personal Data, as set forth in the applicable US State Privacy Law:

·       Right to Delete: The right to request that a "business"/"controller" (each, as defined by the applicable US State Privacy Law) delete, following your verifiable/authenticated consumer request, the specific pieces of Personal Data such business/controller has collected from you.

·       Right to Know/Access: The right to request that a business/controller disclose to you, following your verifiable/authenticated consumer request, some or all of the following (based on your applicable US State Privacy Law):

o   The categories of Personal Data the business/controller has collected about you

o   The categories of sources from which the Personal Data is collected

o   The business or commercial purpose for collecting, selling, or (under CCPA) "sharing" Personal Data

o   The categories of third parties with which the business/controller shares Personal Data

o   The specific pieces of Personal Data the business/controller has collected about you

o   The categories of Personal Data about you that the business/controller disclosed for a business purpose

o   If the business/controller sells or (under CPRA) "shares" your Personal Data:

§  The categories of Personal Data that the business/controller sold or (under CCPA) shared about you

§  The categories of third parties to which your Personal Data was sold or (under CCPA) shared, by category or categories of Personal Data for each category of third parties to which the Personal Data was sold

§  The business or commercial purpose for selling or (under CCPA) sharing Personal Data

·       Right to Correct: The right to request that the business/controller correct any inaccurate Personal Data that it has collected about you

·       Right to Data Portability: The right to be provided with a copy of the Personal Data about you that the business/controller processes by automated means in a portable and, to the extent technically feasible, readily usable format that allows you to transmit it to another party

·       Right to Opt Out: Based on the applicable US State Privacy Law, some or all of the rights discussed as follows:

o   The right to direct a business /controller (as defined by the applicable US State Privacy Law) not to sell (as defined by the applicable US State Privacy Law) or (under CCPA) "share" your Personal Data.

o   The right to opt out of "targeted advertising" (as defined by the applicable US State Privacy Law), which is a type of interest-based advertising.

Note, these opt-out rights are at par with those described above under the header "What Are Your Choices?"

·       Right to Non-Discrimination: the right not to be discriminated against by a business because you exercise any of your rights under your applicable US State Privacy Law, including by:

o   Denying goods or services to you

o   Charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties

o   Providing a different level or quality of goods or services to you

o   Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services

We do not knowingly collect, use, or disclose sensitive Personal Data through or for Vuukle Services.

If you are a resident of a U.S. state with an effective US State Privacy Law, you may submit requests to exercise your "Right to Know/Access", your "Right to Delete", your "Right to Correct", and/or your "Right to Data Portability" by sending an email at privacy@vuukle.com

If you are opted out of interest-based advertising on the applicable web browser upon following Section 10 of this Privacy Policy, we may not be able to verify/authenticate or process your "Request to Delete", your "Request to Know/Access", your "Request to Correct", or your "Request for Data Portability", since we may have no reasonable method of connecting your request with the Personal Data we previously collected about you.

If we notify you that we were unable to verify/authenticate your "Request to Delete", your "Request to Know/Access", your "Request to Correct", or your "Request for Data Portability", you may appeal our determination by emailing us at privacy@vuukle.com and indicating why you disagree with our determination (including by providing additional information to support your request).

If you are a resident of a U.S. state with an effective US State Privacy Law, you may exercise your applicable US State Privacy Law "Right(s) to Opt Out" by following steps discussed in Section 10.2.

Authorized Agents: If you are a resident of a US state with an effective US State Privacy Law, if and as required by that US State Privacy Law, you may use an "authorized agent" to submit requests to exercise your "right to know/access", your "right to delete", your "right to correct", your "right to data portability", and/or your US State Privacy Law "right(s) to opt-out" (as applicable) on your behalf under that US State Privacy Law. Your authorized agent will need to provide us with a copy of a written permission that is signed by you and indicates that you have provided such authorization.

13. Advertising Industry Self-Regulation

Vuukle supports advertising industry self-regulation, and endorses best practices and self-regulatory requirements that apply to the advertising industry. To learn more about interest-based advertising and industry self-regulation, please visit any of the following organizations:

·       EU: European Interactive Digital Advertising Alliance

·       US: Digital Advertising Alliance or Network Advertising Initiative

14. What Happens if this Privacy Statement is Changed?

Please check this page for changes, as we may change this Privacy Statement at any time. If we make changes that we believe are material, those changes will not be applied to information collected prior to the date the changes went into effect.

15. Biometric Information (Face Data)

This section applies only to the Face ID verification feature available on the quizzly.ai/play website, which is operated by Vuukle.

14A. Named Sub-Processors

To deliver the Vuukle Services, we share carefully scoped portions of data with specialist sub-processors. The principal sub-processors we engage today are:

A complete, up-to-date list of sub-processors — including hosting providers, transactional email providers and analytics tooling — is available on request to legal@vuukle.com. Publishers with a signed Data Processing Agreement (DPA) receive 30-day notice of any new sub-processor with the right to object.

15.1 Collection and Use of Biometric Information

When a user chooses to use Face ID verification, we collect and process biometric information in the form of an encrypted facial representation (biometric template). This biometric template is generated for the sole purpose of verifying the user’s identity and enabling authentication.

We do not store raw facial images. Only a unique, encrypted biometric template is created and retained.

Facial data is processed only to:

1. Verify the user's identity during login or authentication.
2. Enable secure account access using Face ID verification.

The biometric template cannot be used to reconstruct the original facial image.

We may also derive limited demographic estimates, such as age range or gender, for analytics and marketing insights. These estimates:

1. Are not used to uniquely identify a user
2. Are used only for aggregate analytics and content personalization

Face ID verification technology is offered only as part of the Quizzly product (Vuukle’s patented contextual AI engine, US Patent No. 12148006B1) where it is used to enable opt-in account authentication for end-users who choose to participate in interactive quizzes. It is provided by our sub-processor FaceIO.net, which processes facial data on Vuukle’s behalf to generate the encrypted biometric template. End-users who do not use Quizzly are not subject to any biometric processing.

The encrypted biometric template may be stored in:

1. Vuukle’s secure systems
2. FaceIO.net’s secure systems

15.2 Retention of Biometric Information

Biometric templates are retained only for as long as necessary to provide authentication services.

Biometric data is stored only while the user account remains active and is automatically deleted when:

1. The user deletes their account
2. The user submits a valid request for personal data deletion
3. Face ID authentication is disabled for the account

Upon such request or account deletion, biometric templates are permanently deleted from both Vuukle’s systems and FaceIO.net’s systems without undue delay.

We do not store biometric information indefinitely.

15.3 Disclosure of Biometric Information

Biometric templates are disclosed only to FaceIO.net, which provides the facial authentication technology used by the service.

No other third parties receive or have access to biometric templates.

Biometric data is not sold, rented, or used for advertising profiling.

15.4 Purpose of Disclosure

Biometric data is shared with FaceIO.net solely to:

1. Generate encrypted biometric templates
2. Authenticate users during login or verification

This disclosure is necessary to enable Face ID verification functionality.

15.5 Third-Party Storage and Practices

FaceIO.net stores encrypted biometric templates solely to provide identity verification services. FaceIO.net:

1. Does not store raw facial images
2. Stores only encrypted biometric templates
3. Retains biometric templates only as long as necessary to provide authentication services
4. Does not share, sell, rent, or loan biometric data to third parties
5. Cannot access or decrypt your facial hashes, which are handled only by the application’s underlying Facial Recognition Engine

When Vuukle receives an account deletion request or deletes an account, Vuukle immediately initiates deletion of the biometric template from FaceIO.net’s systems.

For more information, please refer to FaceIO.net’s Privacy Policy, specifically the “Disclosing Your Information to Third Parties” section: https://faceio.net/privacy-policy

16. Contact Information

If you have any questions about this Privacy Statement or our data protection practices, or if you would like to contact our data protection representative, please feel free to contact us at privacy@vuukle.com