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player preferences using embedded YouTube
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PRIVACY POLICY

We, at Cloudinary Ltd. and its affiliates, put great efforts in making sure that
we secure your personally identifiable information and use it properly.

This policy explains our privacy practices for processing your personally
identifiable information as a user of our Cloudinary cloud-based image
management solution, on the Cloudinary website and through other registration or
contact channels (the “Service”). We process your personally identifiable
information subject to the terms of this policy.

The summary of this policy will give you a quick and clear view of our
practices. Please take the time to read our full policy.


A SUMMARY OF THE POLICY

The Personally Identifiable Information That You Provide Us – We receive and
store any information you enter on our website or give us in any other way. If
you register with the Service we will need your name, your company name, email
address and password, for registration and notice purposes; your payment details
to process your payment for the service and we will receive any personally
identifiable information that you provide when contacting us. Read more.

The Personally Identifiable Information That We Collect – We automatically log
‘traffic/session’ information including IP addresses and user agent. We collect
session durations and additional activity information. Read more.

The Personally Identifiable Information That You Upload – You can upload content
with personally identifiable information. Please use caution and do not upload
personally identifiable information of others without their appropriate consent.
Read more.

What Do We Do With Personally Identifiable Information? – We maintain the
Service, make it better and continue developing it, and protect us and the
Service from misuse and law violations. Read more.

Sharing Personally Identifiable Information with Others – We use service
providers, for example, to process payments and send email messages. We will
transfer information when we change our corporate structure, and we will share
the information with our affiliate entities. Read more.

Disclosure of Information to Authorities – We will obey orders and other lawful
requirements by authorities to disclose information. Read more.

Aggregated and Analytical Information – Aggregated data is not identifiable. We
use it for legitimate business purposes and for standard analytical tools. Read
more.

Your Choice – You may opt-out of our mailing lists and terminate your use of the
Service. Our Service does not respond to Do Not Track (DNT) signals. Read more.

Specific Provisions for California Residents – If you are a California resident,
you are entitled to specific privacy rights. Read more.

Accessing Your Personally Identifiable Information – At any time you can request
access to your personally identifiable information. Read more.

Your EU Data Subject Rights – If we process your personal data when you are in
the EU, further terms apply to our processing in relation to your rights as a
data subject under EU data protection laws. Read more.

Data retention – We retain data to provide the service and for legitimate and
lawful purposes, as further explained in the data retention section of the
policy. Read more.

Transfer of Data Outside your Territory – We use cloud based services to store
and process data in the European Union and in the United States and will store
them at additional sites, at our discretion. These service providers provide us
adequate security and confidentiality commitments. Read more.

Cookies – We use cookies to make it easier for you to log-in and to facilitate
Service activities. Read more.

Information Security – We implement systems, applications and procedures to
secure your personally identifiable information, to minimize the risks of theft,
damage, loss of information, or unauthorized access or use of information. Read
more.

Dispute Resolution – Contact us at: privacy@cloudinary.com or write us for every
request and complaint. We will make good-faith efforts to resolve any existing
or potential dispute with you. Read more.

Changes to this Privacy Policy – We will update our policy from time to time
after giving proper notice. Read more.

Incorporation to the Terms of Use – This policy is an integral part of the
Cloudinary Terms of Use or, if applicable, of any other Service subscription
agreement entered into between you (or the entity that you are acting on its
behalf) and us.

Contact Us – Please contact us at: privacy@cloudinary.com for further
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THE CLOUDINARY PRIVACY POLICY


THE PERSONALLY IDENTIFIABLE INFORMATION THAT YOU PROVIDE US

We receive and store any information you enter on our website or give us in any
other way.

You provide most of your information through forms you fill out to contact us,
access the Cloudinary platform, and access Cloudinary assets. You also provide
this information by filling out your profile on the Cloudinary platform.

If you register with the Service through our website at: www.cloudinary.com, or
through a separate subscription agreement with us, then as part of such
registration we will ask you to provide personally identifiable information,
including your name, your company name, your email address and password.

As a paying user of the Service, we will receive your payment transaction
details (for example, your name, the amount paid and the date of payment), from
the payment service provider that processed your payment.

When you contact us, or when we contact you, we will receive and process any
personally identifiable information that you provide us.



THE PERSONALLY IDENTIFIABLE INFORMATION THAT WE COLLECT

Like many websites, we use “cookies” (for further information about cookies,
please see our Cookies and Similar Tracking Technologies Policy), and we obtain
information when your browser accesses our website.

Examples of the information we collect and analyze include the Internet Protocol
(IP) address used to connect your access device to the Internet; login; e-mail
address; password; access device and connection information such as browser
type, version, and time zone setting, browser plug-in types and versions,
operating system, and platform.

When you use the Service, we collect information about your Service activity,
for example your log-in and log-out time, the duration of Service sessions, the
content uploaded and downloaded, viewed web-pages or specific content on
web-pages, activity measures and geo-location.



THE PERSONALLY IDENTIFIABLE INFORMATION THAT YOU UPLOAD

The content you upload to the Service, whether from your own device or from a
cloud-based hosting service, including any data, text, graphic, audio and
audio-visual files, may include personally identifiable information. The content
that you upload and designate as public, will be accessible to others.

Please use caution when uploading the content and avoid any involuntary
disclosure of your personally identifiable information or disclosure of
sensitive personally identifiable information or disclosure of others’
personally identifiable information without their consent.



WHAT DO WE DO WITH PERSONALLY IDENTIFIABLE INFORMATION?

We use the personally identifiable information we collect and receive to provide
the Service to you and to other users, to enable the Service’s tools and
features, to study and analyze the functionality of the Service and users’
activities, to provide support, to measure Service activity for pricing
purposes, to maintain the Service, to make it better and to continue developing
the Service.

We will use your email address to contact you when necessary, to send you
reminders and to provide you information and notices about the Service. We will
include commercial and marketing information about our Service and related
services to the Cloudinary platform.

We obey the law and expect you to do the same. If necessary, we will use your
personally identifiable information to enforce our terms, policies and legal
agreements, to comply with court orders and warrants, and assist law enforcement
agencies, to collect debts, prevent fraud, misappropriation, infringements,
identity thefts and any other misuse of the Service, and to take any action in
any legal dispute and proceeding.

We commit to process personally identifiable information solely for the purposes
described in this policy.



SHARING PERSONALLY IDENTIFIABLE INFORMATION WITH OTHERS

We do not sell, rent or lease your personally identifiable information. We will
share your personally identifiable information with service providers and other
third parties, if necessary to fulfill the purposes for collecting the
information. Any such third party will commit to protect your privacy as
required under the applicable law and this policy.

For example, we will share your payment transaction details with the payment
services providers, to process and verify your payments. We will use a service
provider to manage our email messages transmission.

We will also share your personally identifiable information with our affiliates.
These mean companies within the Cloudinary group and include subsidiaries,
sister-companies and parent companies, with the express provision that their use
of your personally identifiable information will comply with this policy.

We will report any content that you upload and share user personally
identifiable information, if we believe, in our sole discretion that such
content is illegal or abusive or may violate any third party rights.

Additionally, a merger, acquisition or any other structural change will require
us to transfer your personally identifiable information to another entity, as
part of the structural change, provided that the receiving entity will comply
with this policy.



DISCLOSURE OF INFORMATION TO AUTHORITIES

We will need to disclose personally identifiable information in response to
lawful requests by public authorities, including to meet national security or
law enforcement requirements.



AGGREGATED AND ANALYTICAL INFORMATION

We use standard analytics tools. The privacy practices of these tools are
subject to their own privacy policies and they use their own cookies to provide
their service (for further information about cookies, please see the ‘Cookies’
section in this policy).

We use the standard analytics tools of Google Analytics and we will use
additional or other analytics tools, from time to time, to learn about how you
and other users use the Service, in support of our Service-related activities
and operations.

The privacy practices of these tools are subject to their own privacy policies.
See Google Analytics Privacy Policy at:
http://www.google.com/analytics/learn/privacy.html.

We use anonymous, statistical or aggregated information and will share it with
our partners for legitimate business purposes. It has no effect on your privacy,
because there is no reasonable way to extract data from the aggregated
information that we or others can associate specifically to you.

We will share your personally identifiable information only subject to the terms
of this policy, or subject to your prior consent.



YOUR CHOICE

At any time, you can unsubscribe our mailing lists or newsletters, by accessing
our unsubscribe page at: http://info.cloudinary.com/UnsubscribePage.html.

At any time, you can stop using the Cloudinary website. Termination of your
Cloudinary Service account is subject to the terms of your subscription
agreement with us.

Note that if one of our customers uploaded content to our Service with your
personally identifiable information, then you can contact our customer who
uploaded that content and request to remove your personally identifiable
information.

At any time, you can exercise your following opt-out options:

 1. object to the disclosure of your personally identifiable information to a
    third party, other than to third parties who act as our agents to perform
    tasks on our behalf and under our instructions; or,
 2. object to the use of your personally identifiable information for a purpose
    that is materially different from the purposes for which we originally
    collected such information, pursuant to this policy, or you subsequently
    authorized such use.

You can exercise your choice by contacting us at: privacy@cloudinary.com.

We request and collect minimal personally identifiable information that we need
for the purposes that we describe in this policy. Following the termination or
expiration of the Service, we will stop collecting any personally identifiable
information from or about you.

However, we will store and continue using or making available your personally
identifiable information according with our data retention section in this
policy.

Web browsers offer a “Do Not Track” (“DNT”) signal. A DNT signal is a HTTP
header field indicating your preference for tracking your activities on a
service or through cross-site user tracking. Our Service does not respond to DNT
signals.



SPECIFIC PROVISIONS FOR CALIFORNIA RESIDENTS

This section applies solely to users of our Service who reside in the State of
California.

The personal information that we collect

In the preceding twelve (12) months we have collected the following categories
of personal information:

 * Identifiers and Personal information categories listed in the California
   Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, email
   address and IP address.
 * Commercial information, such as payment details.
 * Internet or other similar network activity.
 * Geolocation data.
 * Inferences drawn from other personal information.

Please note that the above list includes the categories of personal information
that we are aware of. We may have been be collecting other categories of
personal information which you have uploaded to our Service as further described
above under the section titled The Personally Identifiable Information That You
Upload.

Our business purposes for collecting your personal information

We collect your personal information for various business purposes, such as to
provide you with the Service and make it better, all as described above under
the section titled What Do We Do With Personally Identifiable Information.

The categories of sources from which your personal information is collected

We obtain the categories of personal information listed above from various
sources, including directly from you and from your Services activities and from
third party service providers, as further described above under the section
titled The Personally Identifiable Information That We Collect.

The categories of third parties with whom we share your personal information

We may share your personal information with various third parties such as our
service providers and our affiliates, as further described above under the
section titled Sharing Personally Identifiable Information with Others.

The categories of personal information disclosed to said third parties:

In the preceding twelve (12) months we have disclosed the following categories
of personal information for business purposes:

 * Identifiers and Personal information categories listed in the California
   Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, email
   address and IP address.
 * Commercial information, such as payment details.
 * Internet or other similar network activity.
 * Inferences drawn from other personal information.

In the preceding twelve (12) months, we have not sold personal information.

Your Rights as a California Resident

You are entitled to the following specific rights under the California Consumer
Privacy Act (‘CCPA’) in relation to your personal information:

Access to Specific Information and Data Portability Rights

You have the right to request that we will disclose certain information to you
about our collection and use of your personal information over the past 12
months. After verifying your request, we will disclose to you:

 * The categories of personal information we collected about you;
 * The categories of sources for the personal information we collected about
   you;
 * Our business or commercial purpose for collecting that personal information;
 * The categories of third parties with whom we share that personal information;
 * The specific pieces of personal information we collected about you;
 * If we disclosed your personal information for a business purpose, we will
   provide you with a list which will identify the personal information
   categories that each category of recipient obtained.

Deletion Rights

You have the right to request that we delete your personal information. Upon
confirmation of your request, we will delete (and direct our service providers
to delete) your personal information from our records, unless an exception under
applicable law applies.

Exercising Your Rights

To exercise the access, data portability, and deletion rights described above,
please submit your request to us by sending an email to: privacy@cloudinary.com.

Only you or a person authorized to act on your behalf, may make a request
related to your personal information. You may also make a verifiable consumer
request on behalf of your minor child.

A request for access can be made by you only twice within a 12-months period.

We cannot respond to your request or provide you with the requested personal
information if we cannot verify your identity or authority to make the request
and confirm the personal information relates to you. We will only use the
personal information provided in your request to verify your identity or
authority to make the request.

We will do our best to respond to your request within 45 days of its receipt. If
we require more time (up to additional 45 days), we will inform you of the
reason and extension period in writing. If you do not have an account with us,
we will deliver our written response by mail or electronically, at your option.

Any disclosures that we provide will only cover the 12-month period preceding
receipt of your request.

The response we provide will also explain the reasons for our inability to
comply with your request, if applicable.

We do not charge a fee to process or respond to your request unless it is
excessive, repetitive, or manifestly unfounded. If we determine that the request
warrants a fee, we will inform you of the reasons for such decision and provide
you with a cost estimate before processing further your request.



ACCESSING YOUR PERSONALLY IDENTIFIABLE INFORMATION

If you find that the information on your account is not accurate, complete or
up-to-date, please provide us the necessary information to correct it.

At any time, you can contact us at: privacy@cloudinary.com and request to access
the personally identifiable information that we keep about you. We will ask you
to provide us certain credentials to make sure that you are who you claim to be
and to the extent required under the applicable law, will make good-faith
efforts to locate your personally identifiable information that you request to
access..

If you are eligible for the right of access under the applicable law, you can
obtain confirmation from us of whether we are processing personally identifiable
information about you, and receive a copy of that data, so that you could –

 * verify its accuracy and the lawfulness of its processing;
 * request the correction, amendment or deletion of your personally identifiable
   information if it is inaccurate or if you believe that the processing of your
   personally identifiable information is in violation of the applicable law.

We will use judgement and due care to redact from the data which we will make
available to you, personally identifiable information related to others.



YOUR EU DATA SUBJECT RIGHTS

If EU data protection laws apply to the processing of your personal data by
Cloudinary, then the following terms apply:

For the purposes of the Cloudinary media management platform service, we are a
data processor and our customers are data controllers, or data processors as
well. Cloudinary’s data processing addendum, which is available at:
https://cloudinary.com/gdpr/dpa, applies to such processing.

Where we process your personal data as a data controller, the processing is
based on the following lawful grounds:

 * All processing of your personal data which are not based on the lawful
   grounds indicated below, are based on your consent.
 * We process your account and payment details to perform the contract with you.
 * We will process your personal data to comply with a legal obligation and to
   protect your and others’ vital interests.
 * We will further rely on our legitimate interests, which we believe are not
   overridden by your fundamental rights and freedoms, for the following
   purposes:
   * Communications with you, including direct marketing where you are our
     client or a user of our client, or where you make contact with us through
     our website and other digital assets.
   * Cyber security
   * Support, customer relations, service operations
   * Enhancements and improvements to yours and other users’ experience with our
     services.
   * Fraud detection and misuse of the Service.

In addition to your rights under other sections in this policy, you have the
following rights:

 * AT ANY TIME, CONTACT US IF YOU WANT TO WITHDRAW YOUR CONSENT TO THE
   PROCESSING OF YOUR PERSONAL DATA. EXERCISING THIS RIGHT WILL NOT AFFECT THE
   LAWFULNESS OF PROCESSING BASED ON CONSENT BEFORE ITS WITHDRAWAL.
 * Request to delete or restrict access to your personal data. We will review
   your request and use our judgment, pursuant to the provisions of the
   applicable law, to reach a decision about your request.
 * If you exercise one (or more) of the above-mentioned rights, in accordance
   with the provisions of applicable law, you may request to be informed that
   third parties that hold your personal data, in accordance with this policy,
   will act accordingly.
 * You may ask to transfer your personal data in accordance with your right to
   data portability.
 * You may object to the processing of your personal data for direct marketing
   purposes. Additional information about this right is available under the
   Choice section in this policy.
 * You have the right not to be subject to a decision based solely on automated
   processing, including profiling, which produces legal effects concerning you
   or similarly significantly affecting you.
 * You have a right to lodge a complaint with a data protection supervisory
   authority of your habitual residence, place of work or of an alleged
   infringement of the GDPR.

A summary and further details about your rights under EU data protection laws,
is available on the EU Commission’s website at:
https://ec.europa.eu/info/law/law-topic/data-protection/reform/rights-citizens_en.

Note that when you send us a request to exercise your rights, we will need to
reasonably authenticate your identity and location. We will ask you to provide
us credentials to make sure that you are who you claim to be and will further
ask you questions to understand the nature and scope of your request.

If we need to delete your personal data following your request, it will take
some time until we completely delete residual copies of your personal data from
our active servers and from our backup systems.

If you have any concerns about the way we process your personal data, you are
welcome to contact our privacy team at: privacy@cloudinary.com. We will look
into your inquiry and make good-faith efforts to respond promptly.



DATA RETENTION

We retain different types of personally identifiable information for different
periods, depending on the purposes for processing the information, our
legitimate business purposes as well as pursuant to legal requirements under the
applicable law.

For example, we will need to keep the information about the payment transactions
that you made for several years due to tax related requirements, for accounts
settling, record keeping, archiving and legal issues.

We will maintain your contact details, to help us stay in contact with you. At
any time before or after the termination of your account, you can contact our
privacy team at: privacy@cloudinary.com and request to delete your contact
details. Note that we may keep your details without using them unless necessary,
and for the necessary period of time, for legal requirements and proceedings.

We will keep aggregated non-identifiable information without limitation, and to
the extent reasonable we will delete or de-identify potentially identifiable
information, when we no longer need to process the information.

In any case, as long as you use the Service, we will keep information about you,
unless the law requires us to delete it, or if we decide to remove it at our
discretion, according to the terms of this policy.



TRANSFER OF DATA OUTSIDE YOUR TERRITORY

The Service is a web-based service. We store and process information, either
directly or using third parties, such as data hosting service providers, in the
European Union, the United States, the United Kingdom and Singapore. The laws of
these territories may differ from the laws of the jurisdiction in which you
live.

We make sure that our third-party service providers, provide us with adequate
confidentiality and security commitments and we will take all steps reasonably
necessary to ensure that personally identifiable information related to you is
treated securely and in accordance with this privacy policy.

If you are a resident in a jurisdiction where transfer of your personally
identifiable information to another jurisdiction requires your consent, then you
provide us your express and unambiguous consent to such transfer.

If you are located in the European Economic Area (EEA), note that we will
transfer personal data related to you to other jurisdictions, which are not
deemed to provide an adequate level of data protection. In such case, we will
use appropriate safeguards, in particular, by way of entering into the European
Union (EU) Standard Contractual Clauses as amended from time to time with the
relevant recipients, or by adhering to equivalent data transfer regulations to
protect the security and confidentiality of such personal data. You can obtain a
copy of the suitable safeguards that we use when transferring personal data as
described above or receive further information about data transfer by contacting
us at: privacy@cloudinary.com.



COOKIES

We use cookies and similar tracking technologies to make sure that our Service
is continuously improved and meets your needs.

Please view our Cookies and Similar Tracking Technologies Policy for more
information on our use of cookies.




INFORMATION SECURITY

We and our hosting services implement systems, applications and procedures to
secure your personally identifiable information, to minimize the risks of theft,
damage, loss of information, or unauthorized access or use of information.

These measures provide sound industry standard security. However, although we
make efforts to protect your privacy, we cannot guarantee that the Service will
be immune from any wrongdoings, malfunctions, unlawful interceptions or access,
or other kinds of abuse and misuse.




DISPUTE RESOLUTION

We do periodical assessments of our data processing and privacy practices, to
make sure that we comply with this policy, to update the policy when we believe
that we need to, and to verify that we display the policy properly and in an
accessible manner. If you have any concerns about the way we process your
personally identifiable information, you are welcome to contact our privacy team
at: privacy@cloudinary.com, or write to us. Our address is published on our
website at: www.cloudinary.com and, if applicable, is indicated in your
subscription agreement with us.

We will look into your query and make good-faith efforts to resolve any existing
or potential dispute with you.



CHANGES TO THIS PRIVACY POLICY

From time to time, we will update this policy. If the updates have minor if any
consequences, they will take effect 7 days after we post a notice on the
Service’s website. Substantial changes will be effective 30 days after we
initially posted the notice.

Until the new policy takes effect, if it materially reduces the protection of
your privacy right under the then-existing policy you can choose not to accept
it and terminate your use of the Service. Continuing to use the Service after
the new policy takes effect means that you agree to the new policy. Note that if
we need to adapt the policy to legal requirements, the new policy will become
effective immediately or as required by law.


INCORPORATION TO THE TERMS OF USE

This policy is an integral part of the Cloudinary Terms of Use or, if
applicable, of any other Service subscription agreement entered into between you
(or the entity that you are acting on its behalf) and us.


CONTACT US

Please contact our Privacy Compliance Team and our EU Representative (Cloudinary
UK Ltd.) at: privacy@cloudinary.com for further information.

Last updated: Oct 13, 2021.

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