PRIVACY POLICY

SHEER

Last Updated: Aug 02, 2022

We, Media Enterprises, s.r.o. (“Media Enterprises”), a company registered and existing under the laws of the Czech Republic, with registration number 140 01 381, having its registered office at Krakovska 1366/25, 110 00 Prague 1, Czech Republic, registered in the Commercial Register administered by the Municipal Court in Prague, Section C, Inset 189029 the provider of the website www.sheer.com (hereinafter referred to as the “Website”). The provider of the Website is the responsible data controller in the sense of Article 4(7) of European Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the “GDPR”).

This privacy policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Website. We process personal data only in accordance with this privacy policy. By accessing the Website, you acknowledge that you have read this privacy policy and understand that your personal data may be processed.

By accessing this Website and creating an account, you consent to Media Enterprises processing your personal data.

1. INFORMATION WE COLLECT

Personal data refers to any information that tells us something about you or that allows us to identify you, including your name, location data, and online identifiers.

We processes the following categories of information:

1.1 Information You Give to Us.

We collect your personal information that we receive from you when you use the Website, including personal information you provide to us including when you: watch a video, enquire or make an application for our services, register to use and/or use any of our services and when you communicate with us through email, the Website or portal, or any other electronic means.

Such information may include:

• your name including first name and family name, email address, billing address, username, password, etc.;

1.2 Information We Automatically And Necessarily Collect from Your Use of the Website.

We collect information about the services that you use and how you use them, such as when you watch a video on the Website, visit a website that uses our advertising services or view or interact with our ads and content. This information includes:

• Device information. We collect device specific information such as IP address, access dates and times, hardware and software information, device information and cookie data.
• Geo-location Information. When you use certain features of the Website, we may collect information about your approximate location as determined through data such as your IP address.
• Usage Information. We collect information about your interactions with the Website such as the content you view, your searches queries and other interactions with the Website.
• Cookies and Similar Technologies. We use cookies and other similar technologies. For more information on our use of these technologies, see our Cookie Policy, available at https://www.sheer.com/cookie-notice.

1.3 Information We Collect from Third Parties and Third-Party Links.

We may collect information, including personal information that others provide about you when they use the Website, or obtain information from other sources and combine that with information we collect through the Website. We do not control or supervise and are not responsible for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be directed to such third parties.

Furthermore, to the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information and combine it with information we have about you.

Please note that this Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control or supervise these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every site you visit.

1.4 Accuracy of Information.

It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. HOW WE USE INFORMATION WE COLLECT

We use, store, and process information, including personal information, about you to provide, understand, improve, and develop the Website, to protect us and our users and to comply with our legal obligations. We also use this information to offer you tailored content – like giving you more relevant search results and ads.

2.1 Provide, Improve, and Develop the Website.

• Enable you to access and use the Website.
• Enable you to communicate with other users.
• Operate, protect, improve, and optimize the Website, such as by performing analytics and conducting research, undertaking internal research for technological development and demonstration.
• Provide customer service.
• Send you service or support messages, updates, security alerts, and account notifications.
• To operate, protect, improve, and optimize the Website, and personalize and customize your experience (such as making suggestions or ranking search results)

Lawful bases: we rely on the following three lawful bases to process your personal data for the specific purpose of providing, improving and developing the Website as described above.

1. we process this information in order to adequately perform the contract with you;
2. our legitimate business interests in processing your personal data, specifically for the purpose of improving the Website and our users’ experience with it, which we have determined can only be achieved by processing your personal data. We consider the processing of your personal data to be proportionate with your interests, rights and freedoms;
3. to the extent necessary to perform our contract with you and customise your experience

2.2 Protect us and our Users and Comply with Legal Obligations.

• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments, including any reports third parties may file about you.
• Comply with our legal obligations.
• Resolve any disputes with any of our users and enforce our agreements with third parties.
• Enforce our Terms of Service and other policies.

Lawful bases: we rely on the following three lawful basis to process your personal data:

1. legal obligations to which we are subject, which may include disclosing your personal data to a third party or competent national authorities.
2. legitimate interests in protecting our business, which includes protecting the Website and our reputation as a law-abiding business to the extent appropriate. We consider the processing of your personal data to be proportionate with your interests, rights and freedoms.

2.3 Provide, Personalize, Measure, and Improve our Advertising and Marketing.

• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Website).
• Personalize, measure, and improve our advertising based on your characteristics and preferences (based on the information you provide to us, your interactions with the Website, information obtained from third parties, and your search and viewing history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

Lawful bases: we rely on the following two lawful bases to process your personal data:

1. We process your personal information for the purposes listed in this section given our legitimate interest in undertaking marketing activities to offer you products or services that may be of your interest. We consider the processing of your personal data to be proportionate with your interests, rights and freedoms.

You can opt-out of receiving marketing communications from us by following the unsubscribe instructions included in our marketing communications or changing your notification settings within your account.

2.4 Your direct contact with us through our Website or by post, phone, email or otherwise

• Respond to your queries regarding service or your complaints.
• Provide you with further information on privacy policy.
• Any other queries you may have for which you contact us.

Lawful bases: when you contact us directly through our Website or by post, phone, email or otherwise, including for the purposes of exercising your rights under the GDPR or to file any complaints, we will rely on the following two bases to process your personal data:

1. We will rely on our legitimate interests as a customer-friendly entertainment business that wants to improve the experience of the customers using our Website, to resolve satisfactorily any complaints made by our customers, or to respond to any requests for further information. We will process your personal data we deem necessary for these legitimate interests. Additionally, in rare cases where we reasonably determine that your direct communications with us or our staff are or become abusive, amount to harassment or otherwise illegal under the applicable laws, we may also process your personal data for these purposes and pass it onto the relevant governmental authorities. We consider the processing of your personal data to be proportionate with your interests, rights and freedoms.
2. We may also need to rely on our legal obligations to process your personal data in cases where the applicable law compels us to communicate your personal data exchanged in direct communications with us to the responsible governmental authorities.

3. COOKIES POLICY AND GOOGLE ANALYTICS

Our Website uses session cookies and persistent cookies. To learn more about cookies, please visit our cookies policy, which explains how you can manage your preferences.

4. SECURITY

Note that all data is kept in a secure environment. We protect personal data by using appropriate safeguard procedures and measures, in particular:

• We encrypt our services using SSL.
• We use firewalls to protect your information.
• We review our information collection, storage and processing practices regularly, including physical security measures, to guard against unauthorised access to systems.
• We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual or other legal confidentiality obligations.

If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your account, please contact us following the instructions in the Contact Us section below.

We require age verification check of our users to ensure that we do not knowingly offer our Services to or collect personal data from anyone under 18 or anyone using a false identity. The verification check involves providing certain information to our third party payment providers. Please note that when you make a payment that is processed by a payment provider, you will provide that third party with your credit card number, credit card expiration date, and security code, which they process and store subject to their privacy policy and terms of service. We do not receive your full credit card number, credit card expiration date, or the security code. If you are required to provide your name and email address to the payment provider, then they also provide us with that information.

5. YOUR RIGHTS

You may exercise any of the rights described in this section by adjusting settings in your user account and, if it is not possible, you can contact us at our above mentioned address. Please note that we will ask you to verify your identity before taking further action on your request, and if we cannot identify you we cannot act according to your request.

5.1 Managing Your Information.

You may access and update some of your information through your account settings. You are responsible for keeping your personal information up-to-date in a secure place.

5.2 Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your account) by contacting us at the address listed in the Contact Us section below.

5.3 Data Access and Portability.

You have a right to request copies of your personal information held by us (although not necessarily in the same format held by us). You are also entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

5.4 Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us, to protect our legitimate interest or legitimate interest of a third party and to comply with our legal obligations on data retention as provided by the applicable laws. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means.

If you no longer want us to use your information to provide you the service, you can request that we close your account and erase your personal data. Please note that if you request the erasure of your personal information:

• most of the data are deleted right after account deletion, but we keep some information such as (email / login / IP) for one year after deletion as necessary for our legitimate business interests, such as fraud detection and prevention, copyright infringement and enhancing safety. For example, if we suspend an account for fraud or safety reasons, or based upon alleged copyright infringement, we may retain certain information from that account to prevent that user from opening a new account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations.
• Information you have shared with others (e.g., likes, forum postings) may continue to be publicly visible on the Website, even after your account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Website to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

5.5 Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us, you may withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Additionally, you have the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 5.6 and pending the verification whether the legitimate grounds of the Website provider override your own.

5.6 Objection to Processing.

You have a right to require us not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims.

5.7 Lodging Complaints.

You have the right to file a complaint about the data processing activities carried out before the competent data protection authorities either in your country of residence if that country is a member of the EEA or with the Czech Data Protection Office, where Media Enterprises is headquartered. More information about the Czech Data Protection Office is available at https://www.uoou.cz/en/

6. OPERATING GLOBALLY

Where we transfer, store and process your personal data outside of the EEA we have ensured that appropriate safeguards are in place to ensure adequate level of data protection. We rely on EU Model Clauses and adequacy decisions issued by competent European authorities. If we are unable to rely on these two bases, we will transfer data outside the EEA to the extent doing do is: (a) necessary for the performance of a contract between you and us; (b) necessary for the conclusion or performance of a contract concluded for your interest between us and another natural or legal person; (c) necessary for the establishment, exercise or defence of legal claims; or (d) any other bases listed in Article 49 of the GDPR if applicable, such as seeking your consent.

We share certain data with the following groups of recipients to the extent we deem it necessary to be able to perform our operations or are compelled to do by law:

• Government authorities;
• Third party service providers;
• Financial institutions;
• Providers of storage systems;
• IT services providers;
• Providers of services necessary for the performance of our activity (administrative activities, archiving, legal advice, receivables management, etc.).

7. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Website and update the “Last Updated” date at the top of this Privacy Policy. For the individuals who have created an account on or through this Website (i.e., those individuals who fall within the Category 2, Category 3, or Category 4 of users listed on page 1 of this privacy policy), we will also send you an email to inform you of any changes. If you disagree with the revised privacy policy, you may cancel your account. If you do not cancel your account before the date the revised privacy policy becomes effective, your continued access to or use of the Website will be subject to the revised privacy policy.

8. CONTACT US

You may contact us at:

   Media Enterprises Czech Republic, a.s, Att. of Data Privacy Officer

Email address: support@sheer.com

Postal address:

   Krakovska 1366/25

   Prague 1

   Czech Republic

POLICY FOR ADDRESSING THE DISSEMINATION OF TERRORIST CONTENT

Last Updated: Aug 02, 2022

We, Media Enterprises TV, s.r.o., having its registered office at Krakovská 1366/25, Nové Město, 110 00 Prague 1, Czech Republic, Business registration No. (IČO): 140 01 381, registered in the Commercial Register administered by the Municipal Court in Prague, Section C, Inset 189029 (hereinafter referred to as the “Provider” or „we“), the provider of the website www.sheer.com (hereinafter referred to as the “Website”) are committed to actively participate in addressing the dissemination of terrorist content online. Any content intended to praise, promote, or aid terrorist or any other violent criminal organizations is strictly prohibited on the Website. These organizations are not allowed to use the Website for any purpose, including recruitment.

1. What is Terrorist Content?

In particular, we consider terrorist content to be any content that:

(I) incites the commission one of the following terrorist offences:

• attacks upon a person’s life which may cause death;
• attacks upon the physical integrity of a person;
• kidnapping or hostage-taking;
• causing extensive destruction to a government or public facility, a transport system, an infrastructure facility, including an information system, a fixed platform located on the continental shelf, a public place or private property likely to endanger human life or result in major economic loss;
• seizure of aircraft, ships or other means of public or goods transport;
• manufacture, possession, acquisition, transport, supply or use of explosives or weapons, including chemical, biological, radiological or nuclear weapons, as well as research into, and development of, chemical, biological, radiological or nuclear weapons;
• release of dangerous substances, or causing fires, floods or explosions, the effect of which is to endanger human life;
• interfering with or disrupting the supply of water, power or any other fundamental natural resource, the effect of which is to endanger human life;
• illegal system interference and/or data interference, where a significant number of information systems have been affected and/or a serious damage has been caused and/or were committed against a critical infrastructure information system;
• threatening to commit any of the above listed acts;

(hereinafter collectively referred to as the “Terrorist Offences”) where such content, directly or indirectly, such as by the glorification of terrorist acts, advocates the commission of Terrorist Offences, thereby causing a danger that one or more Terrorist Offences may be committed;

(II) solicits a person or a group of persons to commit or contribute to the commission of one of the Terrorist Offences;

(III) solicits a person or a group of persons to participate in the activities of a terrorist group;

(IV) provides instruction on the making or use of explosives, firearms or other weapons or noxious or hazardous substances, or on other specific methods or techniques for the purpose of committing or contributing to the commission of one of the Terrorist Offences;

(V) constitutes a threat to commit one of the Terrorist Offences;

(VI) depicts the insignia, logos, or symbols of violent criminal or terrorist organizations in order to praise or promote them.

This anti-terrorist content policy applies to photos, videos, video descriptions, comments, live streams, chat messages and any other content or feature of the Website. Keep in mind that this isn't a complete list. Please note that this policy also applies to external links in your content. This can include clickable URLs, verbally directing users to other sites, as well as other forms.

2. How to Address Terrorist Content?

If you find content on our Website that violates this policy, please report it using the form at https://www.sheer.com/support. Any content we suspect might represent terrorist content will be removed and reported to law enforcement in accordance with the applicable laws.

The Provider has established a contact point for the receipt and processing of official removal orders concerning terrorist content issued by the competent state authorities: https://www.sheer.com/support. This contact point may be addressed in English and Czech language. After receiving the official removal order we will make every possible effort to remove the reported terrorist content or disable access to it as soon as possible and in any event within one hour of receipt of the removal order.

3. Changes to this Policy

We reserve the right to modify this policy at any time in accordance with this provision. If we make changes to this policy, we will post the revised policy on the Website and update the “Last Updated” date at the top of this policy.